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

However, women in tax face greater career obstacles than their male counterparts, an exclusive ITR survey of more than 100 women tax leaders revealed
Under Jeff Soar’s leadership, WTS UK aims to scale to 100 partners within five years and challenge the big four
As the firm embarks on a major shakeup of its EMEA partnerships, some staff will be watching nervously
The buyout of Hucke and Associates continues Ryan’s streak of firm acquisitions; in other news, a UK appeal against VAT on private school fees was dismissed
Tax teams are responding to usual client demand in the region, albeit with increased working from home flexibility, local sources indicate
A 120-plus-day delay to refunds would cost taxpayers almost $3bn in additional interest, the Cato Institute warned; plus indirect tax updates from February
The Office for Budget Responsibility’s pessimistic pillar two forecast accompanied the UK chancellor’s muted Spring Statement, dubbed ‘as dull as possible’ by one adviser
Digital tax reform is dissolving the old ‘temporal buffer’, forcing systems, institutions, and professionals to adapt as real-time reporting reshapes governance, capability, and compliance
Our first instalment features analysis of Deloitte’s landmark EMEA merger, Donald Trump’s Supreme Court tariff showdown and Venezuela’s tax evolution
While some believe it could have a positive effect on the wider advisory landscape, others argue that HMRC’s ‘red tape’ exercise won’t deter bad actors
Gift this article