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 2025

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

Awards
Submit your nominations to this year's WIBL EMEA Awards by 6 February 2026
Defending loss situations in TP is not about denying the existence of losses but about showing, through proactive measures, that the losses reflect genuine commercial realities
Further empowerment of HMRC enforcement has been praised, but the pre-Budget OBR leak was described as ‘shambolic’
Michel Braun of WTS Digital reviews ITR’s inaugural AI in tax event, and concludes that AI will enhance, not replace, the tax professional
The report is solid and balanced as it correctly underscores the ambitious institutional redesign that Brazil has undertaken in adopting a dual VAT model, experts tell ITR
The Brazilian law firm partner warns against going independent too early, considers the weight of political pressure, and tells ITR what makes tax cool
The lessons from Ireland are clear: selective, targeted, and credible fiscal incentives can unlock supply and investment
The ITR in-house award winner delves into his dramatic novelisation of tax transformation, and declares that 'tax doesn’t need AI right now'
Recent news of job cuts at EY is symptomatic of how the PwC controversy has tarnished the reputation of the entire ‘big four’
Experts reportedly discussed extending the safe harbour to 2027 to give countries more time to legislate; in other news, Baker McKenzie and Greenberg Traurig made senior tax hires
Gift this article