Managing TP locally and globally – ITR’s TP Special Focus launched

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

Managing TP locally and globally – ITR’s TP Special Focus launched

00ed-as276363528.jpg

Transfer pricing specialists from around the world come together to share solutions and knowledge in ITR’s 21st edition of the Transfer Pricing guide.

Click here to read the 2021 TP Special Focus guide 

 

The global business environment of 2021 looks very different to how it was this time last year. As expected, the COVID-19 pandemic created significant losses for many businesses. Guidance from the OECD was very much welcomed as businesses sought to work out the best ways to address the impact of the pandemic on TP arrangements.

Businesses across the globe continue to face a range of specific TP challenges. Tax experts in Sweden have the added burden of having to comply with Swedish VAT regulation while following the OECD TP Guidelines, which seems like an almost impossible task.

Russian tax authorities issued guidance in February 2021 on auditing intra-group services, and DAC6 implementation in Italy has introduced compliance activities for intermediaries and taxpayers where intra-group arrangements are required.

However, it is not all doom and gloom. COVID-19 has brought about the adoption of digital technologies and transformation quicker than expected and Indonesia is one country, among many, that has seen significant progress in its digital economy.

MNEs are looking to the future beyond the pandemic and are continuing to rise to the challenges of TP documentation requirements that for many includes a detailed value chain analysis, a vital framework for companies when planning and defending TP policies in the future. Of course, reporting requirements also extend to some Latin American countries, which must comply with BEPS Action 13.

There has been a steady increase in international tax disputes, with mutual agreement procedures (MAPs) increasingly becoming the preferred method to resolve TP disputes. However, in South Korea, there are cases in which TP issues cannot simply be addressed by MAP.

Looking further afield at global mobility, it can be argued that the implementation of the BEPS project by the Multilateral Instrument exacerbates tax and employment problems related to the international mobility of employees.

We hope you enjoy reading the 21st edition of our Transfer Pricing guide.

 

Click here to read the 2021 TP Special Focus guide

more across site & shared bottom lb ros

More from across our site

The South Africa vs SC ruling may embolden the tax authority to take a more aggressive approach to TP assessments, an adviser tells ITR
Indirect tax professionals now rate compliance as a bigger obstacle than technology and automation; in other news, Italy approved a VAT cut on art sales
AI-powered tax agents are likely to be the next big development in tax technology, says Russell Gammon of Tax Systems
FTI Consulting’s EMEA head of employment tax and reward tells ITR about celebrating diversity in the profession, his love of musicals, and what makes tax cool
Canadian Prime Minister Mark Carney and US President Donald Trump have agreed that the countries will look to conclude a deal by July 21, 2025
The firm’s lack of transparency regarding its tax leaks scandal should see the ban extended beyond June 30, senators Deborah O’Neill and Barbara Pocock tell ITR
Despite posing significant administrative hurdles, digital services taxes remain ‘the best way forward’ for emerging economies, says Neil Kelley, COO of Ascoria
A ‘joint understanding’ among G7 countries that ‘defends American interests’ is set to be announced, Scott Bessent claimed
The ‘big four’ firm’s inaugural annual report unveiled a sharp drop in profits for 2024; in other news, Baker McKenzie and Perkins Coie expanded their US tax benches
Representatives from the two countries focused on TP as they met this week to evaluate progress under a previously signed agreement – it is understood
Gift this article