Settling into the new normal world of TP controversy

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

Settling into the new normal world of TP controversy

0-editorial-as105946605.jpg

In collaboration with global TP leaders from Deloitte, ITR brings you expert knowledge and solutions to the opportunities and threats that the TP controversy world of today presents.

Click here to read Deloitte's TP Controversy Guide 2021

The Deloitte TP Controversy Guide arrives at a time when new developments, including revisions to the 2017 OECD TP Guidelines, are rapidly creating the new normal for global disputes and litigation.

As businesses across the world continue to deal with the disruption of COVID-19, which in turn may lead to tax controversies, mitigating the risk is key going forward.

More efficient systems to handle mutual agreement procedures and advance pricing agreements will continue to have a significant impact on tax controversies on a global scale. Deloitte’s recent survey, completed by TP experts from more than 55 countries, showed that APAs remain the key tool available for dispute prevention benefitting both taxpayers and tax authorities.

Tax authorities are globally increasingly focused on taxpayers’ intangibles arrangements and TP outcomes. Financial transactions continue to be another active area of TP controversy for tax authorities. COVID-19 will also have a longer-term impact on how multinational corporations operate specifically in relation to the reporting of country-by-country data.

Other themes dominating the controversy landscape are the OECD’s pillar one and pillar two project, which aims to address the complex issues arising from digital businesses, and initiatives to improve multilateral dispute resolution procedures.

At a time of acceleration in TP controversy, there are challenges that may cause concern. Deloitte’s TP controversy teams, across the globe, are well placed to assist companies through these particular challenges.

We hope that you enjoy reading the practical insights explored in the fourth edition of the TP Controversy Guide.

Click here to read Deloitte's TP Controversy Guide 2021

 

more across site & shared bottom lb ros

More from across our site

The new practice, which features former ‘big four’ experience, already has over 20 team members
Speakers from companies including Uber and Stripe told the inaugural AI in Tax Forum to brace for impending changes to how advisers work
Authors from Khaitan & Co dissect a ‘welcome’ ruling, which found that the mere existence of a tax benefit would not, by itself, warrant a principal purpose test
Over two-thirds of survey respondents back the continuation of the UK’s digital services tax, research commissioned by the Fair Tax Foundation also found
Given the US/G7 pillar two deal, the OECD is in danger of being replaced by the UN as the leading global tax reform forum
Cinven’s latest investment follows its acquisition of a stake in Grant Thornton UK in December; in other news, a barrister listed by HMRC as a tax avoidance promoter has alleged harassment
CIT base narrowing measures remain more prevalent than increased CIT rates, the report also highlighted
ITR's parent company, LBG, will acquire The Lawyer, a leading news, intelligence and data-driven insight provider for the legal industry, from Centaur Media
KPMG UK’s Graeme Webster and KPMG Meijburg & Co’s Eduard Sporken outline the 20-year evolution of MAPAs, with DEMPE analyses becoming more prevalent and MAPA requirements growing stricter
Rishi Joshi, of the Institute of Chartered Accountants of India, warns of potential judicial overreach as assets are recharacterised to bypass a legislative exclusion
Gift this article