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Getting ahead of the next transfer pricing challenge

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In collaboration with experts from Deloitte, ITR brings you exclusive insight into how transfer pricing (TP) controversy is evolving as global businesses go through a transformative phase in 2020.

The guide arrives at a pivotal moment as multinationals juggle challenges thrown at them by trade frictions and increasing regulations, amid widespread economic disruption.

The idea of settling into a 'new normal' following the COVID-19 pandemic has forced tax authorities and taxpayers to respond. A number of industries are expecting additional scrutiny and detailed documentation requests to become the norm in the coming years. Businesses also fear that the application of the arm's-length principle could be altered as governments ramp up efforts to yield tax revenues.

In spite of the challenges, innovation and product development among TP professionals is at an all-time high. The use of data analytics has spearheaded efficiency when it has come to audits, while, with the help of fine-tuning, the number of mutual agreement procedures in the EU are on the rise. In Latin America, advance pricing agreements are being promoted and will subsequently raise the confidence of investors in the region.

Meanwhile, the OECD continues to lead multilateral efforts to address problematic themes such as the retrospective application of guidelines and the regulations surrounding financial transactions.

As demands and queries progressively become international, global TP controversy frameworks have strengthened. China, India and South Korea have reinforced their models over the past decade by adopting best practices, while a number of developing economies in Asia and Africa continue the process of formalisation. Four key cases from the recent past: Adecco (Denmark), Cameco (Canada), Glencore (Australia), and Philips (France), have also helped invigorate guidelines.

Across the globe, Deloitte's TP controversy teams are well placed to assist companies through their particular challenges. We hope that you enjoy reading the practical insights explored in the third edition of our Transfer Pricing: Controversy guide.

Click here to read the entire 2020 Deloitte/ITR Transfer Pricing Controversy guide

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An intense period of lobbying and persuasion is under way as the UN secretary-general’s report on the future of international tax cooperation begins to take shape. Ralph Cunningham reports.
Fresh details of the European Commission’s state aid case against Amazon emerge, while a pension fund is suing Amgen over its tax dispute with the Internal Revenue Service.
The OECD’s rules may be impossible for businesses to manage, according to tax experts from companies including Shell.
The UK government is now committed to replacing the ‘super-deduction’ with a 100% capital allowances regime to offset the impact of the corporate tax rise to 25%.
Corporate tax is set to rise in the UK for the first time in decades, but the headline rate remains historically low despite what many observers think.
President Joe Biden’s nominee is set to be confirmed as IRS commissioner for a five-year term.
British companies are waiting to hear the details of what will replace the 130% ‘super-deduction’ next week, while Spain considers stopping a major infrastructure company moving to the Netherlands.
President Joe Biden wants to raise corporate tax and impose a higher stock buyback tax on US businesses, but his budget proposal faces insurmountable obstacles in Congress, writes Ralph Cunningham.
EY is still negotiating the terms of the plan to split its audit and consulting functions, but the future of tax services is reportedly a sticking point.
Country-by-country reporting is the best option for safe harbour provisions under the global anti-base erosion rules, according to tax directors at companies including Standard Chartered Bank and Pernod Ricard.