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Deloitte’s financial services guide: Confronting the new reality

Confronting the new reality

Paul Riley, Samuel Gordon and Ralf Heussner of Deloitte preview ITR’s upcoming financial services guide, produced in collaboration with global transfer pricing (TP) experts from Deloitte.

Click here to read the entire 2020 Deloitte/ITR Financial Services Guide

Financial services firms face a range of challenges in adapting to the changes brought forward in 2020. This includes disruptive technology and the digitalisation of product and customer platforms, regulatory liberalisation in places like China and additional regulatory requirements in places like the EU, and the economic impact of COVID-19 on their own operations and their customers. 

Banking and capital markets, insurance, investment management, and real estate firms are investing more in technology and digital platforms. Such businesses have been adapting their business models to the latest markets and regulatory requirements; and responding to and recovering from COVID-19 in the short-term, while developing a long-term strategy to thrive after COVID-19 subsides.

Deloitte’s global TP network is pleased to sponsor the 2020 edition of ITR’s special focus guide dedicated to the financial services sector. The articles in this series address the key challenges noted above and other trends affecting the financial services sector in 2020 and beyond.

The Deloitte/ITR guide on the TP of financial services will include an interview with Stewart Brant, head of the TP Unit at the OECD Centre for Tax Policy and Administration, for the latest insights into the OECD’s tax agenda. The interview touches base with Brant on the status of the work on the taxation of the digital economy and its relevance to the financial services sector, the OECD/Inclusive Framework on TP guidance related to addressing the impact of COVID-19, the tax dispute prevention/resolution framework, and other key areas.

Senior members from Deloitte’s financial services transfer pricing (FSTP) team will examine the impact of the COVID-19 pandemic on the banking, investment management, and insurance sectors and share insights on how financial services firms are responding to the pandemic.

Another article will spotlight China and examine how the country’s political and regulatory changes will see the end of ownership limits for foreign investors and assess how this will impact existing operating models and TP policies.

Additional articles will revisit the implications for the financial services sector of the OECD guidance on financial transactions, provide an update on the insurance sector with respect to captives, and examine the status of the global transition from existing interbank rates to the alternative risk-free rates.

Finally, Deloitte financial services tax professionals will provide an update on the EU’s mandatory disclosure rules, DAC6, and provide practical insights for the financial services sector.


The Deloitte Financial Services Guide will be launched on ITR platforms on Wednesday, July 29 2020


Paul Riley


Senior partner

Deloitte Australia

T: +61 416 002 516



Paul Riley is the global TP leader and a senior partner in Deloitte Australia’s tax and legal practice. He has more than 33 years of experience, including 10 years with the Australian Taxation Office (ATO) and 23 years in public practice. Paul has held many senior positions during his 19-year career at Deloitte, including roles as managing partner of Deloitte Australia Tax & Legal (2012-2015), Victoria Tax & Legal leader (2011), and Deloitte Asia-Pacific TP leader (2009-2012). He was appointed leader of the global TP practice effective January 2017. In his global role, he is responsible for overseeing Deloitte’s global TP strategy. 

Paul is experienced in all facets of TP, including successfully resolving a number of TP audits and advance pricing agreements (APAs), large-scale global, regional and local documentation studies, and planning for cross-border transactions for many global businesses across in the automotive industry.

Paul has been listed in Euromoney’s Expert Guides for his TP work since 2008. He is a leader in shaping the thinking in the changing Australian tax landscape by regularly submitting Deloitte’s views on policy matters to government.

Samuel Gordon


Senior partner

Deloitte Japan

T: +81 80 3432 9319



Samuel Gordon is a TP/financial services tax partner with Deloitte Tohmatsu Tax Co in Tokyo, Japan. He is the global TP leader for the financial service industry, and serves as regional or global lead TP advisor for clients across three major financial services hubs – Tokyo, Hong Kong SAR, and Singapore. He is a bilingual (English-Japanese) TP professional with more than 20 years of advisory and in-house experience. 

Samuel focuses on TP for financial services industry clients and inter-company treasury issues of all types of clients. He brings to bear his prior in-house experience to help clients enhance their TP and overall tax management. 

Samuel speaks regularly at TP and tax conferences in Tokyo, Hong Kong SAR, Singapore, New York, and London. He is active with several financial services industry associations and has contributed articles to publications. He is listed in Euromoney’s Expert Guides for his TP work.

Ralf Heussner



Deloitte Luxembourg

T: +352 45145 3313



Ralf Heussner is a partner with Deloitte based in Luxembourg. He specialises in the financial services sector and is part of Deloitte’s global financial services leadership team. He has worked for many of the key players in the asset management industry (ranging from the traditional sector to private equity, real estate, and hedge funds), banking, and insurance during his prior tenure in Tokyo, Hong Kong SAR and Frankfurt.

Over the past 18 years, Ralf gained extensive experience advising clients on a range of tax, TP, valuations, and controversy-related engagements. His experience covers TP planning and policy setting, risk reviews, operationalisation, documentation, restructurings, and dispute resolution engagements. He has worked on more than 30 APAs and numerous high-profile controversies on both the local and competent authority levels with authorities in China, the EU, Japan, the US, and other key jurisdictions.

Ralf is a frequent speaker at tax seminars, has participated in consultation projects with various governments about tax reform, and has contributed to thought leadership on TP issues.

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