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

PwC Australia’s response to its tax leaks scandal could give KPMG a useful case study, but so far there’s little sign of positive lessons learned
Tom Goldstein’s attempt to overturn his tax conviction was shot down; in other news, Deloitte promoted several tax partners in Italy
The tax advisory firm becomes the latest member of the Andersen Global network, which has more than 50,000 professionals worldwide
A revised Chapter VII signals a move away from mechanical TP approaches, stressing transaction understanding, functional analysis and context-driven documentation requirements
HMRC’s growing focus on evidencing tax decisions is shifting attention from technical accuracy to governance, requiring businesses to demonstrate how positions were reached and documented
Australia’s Department of Finance will also commission an independent review of KPMG’s governance, culture, ethics and integrity frameworks, it has revealed
In the second instalment of this two-part series, Jayne Stokes takes a practical approach to navigating the capital v revenue question for UK R&D claims for software development, and shares pointers for businesses
ITR's latest podcast considers how transformational the buyout could be in Ryan's quest for global advisory reach and analyses a recent boom in demand for private client advisory services
The event comes at an important moment for professionals dealing with practical realities related to this practice area
Germany’s dogmatic restriction of third-party investment in tax advisory firms will only serve to slow down innovation and access to justice
Gift this article