Editorial: The Ed Sheeran of transfer pricing

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement


Editorial: The Ed Sheeran of transfer pricing

It used to be when one talked about country-by-country reporting (CbCR) and tax transparency, people would look at you like you were some kind of beret-wearing, fist-raising, Trotskyist from Tooting shouting "power to the people!"

Returning to the world of tax and transfer pricing after nearly three years editing a current affairs magazine, I can see how much things have changed. With the OECD's BEPS project in full swing, CbCR is about as mainstream as Ed Sheeran. And just as no fewer than 16 of his songs find themselves dominating the UK Top 20, it is hardly surprising that this year's Transfer Pricing guide is dominated by the rollout of BEPS Actions worldwide.

As Roberto Carlos Rivas and María Carolina Camargo and of PwC explain, Chile is on the front lines of CbCR as it is among the first countries to require multinationals to file a country-by-country report.

The increased transparency brought by such BEPS measures will inevitably lead to more tax disputes, argue Joe Duffy and Tomás Bailey of Matheson as they survey the Irish landscape.

In Japan, Timothy O'Brien, Takuma McNie and Luke Tanner of Deloitte Tohmatsu Tax explore the ins and outs of the new documentation requirements.

In Sweden, we have Johan Rick of KPMG looking at how OECD materials can be used to interpret local law.

Meanwhile, David Forst and Larissa Neumann of Fenwick & West look at all the latest transfer pricing developments to come out of the US, while Shiv Mahalingham of Duff & Phelps rounds up UK changes.

I hope you find this guide useful.

Salman Shaheen

Managing editor

TPWeek.com

more across site & shared bottom lb ros

More from across our site

Jaydeep Menon explains how Frazier & Deeter built a specialist practice which helps UK start-ups expand into the US and why private equity backing is accelerating its ambitions
As joint audits, data sharing and pillar two reshape tax controversy, multinational groups can no longer afford to manage disputes one jurisdiction at a time
Brazil's tax system is being reshaped by VAT , pillar two and TP reform. Fallet explains why those changes convinced him to lead a new practice
The agreement with Daribatech, alongside recent high-profile investment in talent, suggests the firm is gearing up for a significant push in the region
Several factors have led to a steady transition of TP work away from traditional advisers and towards full-service law firms, DLA Piper’s new TP leader says
Julian Balson's departure from EY's Tier 1 tax controversy practice for lower-ranked Fieldfisher represents one of the more eye-catching UK hires of the year
Former IRS commissioner Danny Werfel argues that the biggest obstacle to AI adoption in tax is not technology, but trust, and introduces a practical AI risk framework to help
Howell takes a deep dive into how he led the landmark PepsiCo dispute, discusses the ATO's enforcement priorities, and emphasises KordaMentha's market ambitions
Global tax leader David Linke said that the TaxSim gaming programme could replace aspects of traditional face-to-face learning
Former ATO economist Craig Silverwood is joining from Australian firm MinterEllison
Gift this article