Settling into the new normal world of TP controversy
International Tax Review is part of the Delinian Group, Delinian Limited, 4 Bouverie Street, London, EC4Y 8AX, Registered in England & Wales, Company number 00954730
Copyright © Delinian Limited and its affiliated companies 2024

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 & bottom lb ros

More from across our site

Barbara Voskamp is bullish on hiring local talent to boost DLA Piper’s Singapore practice, and argues that ‘big four’ accountants suffer from a stifled creativity
Chris Jordan also said that nations have a duty to scrutinise the partnership structures of major firms, while, in other news, a number of tax teams expanded their benches
KPMG has exclusive access to the tool for three years in the UK, giving it an edge over ‘big four’ rivals
But the US tax agency’s advice is consistent with OECD guidance and shouldn’t surprise anyone, other experts tell ITR
A survey of more than 25,000 in-house counsel reveals that diversity initiatives are a high priority when choosing external counsel
The report is aimed at helping 'low-capacity countries', the OECD has claimed
The UK tax agency appears to be going after easier, lower value targets, one lawyer has claimed
Criminal experts have told ITR that the case of Ulf Johannemann emphasises the fine line between tax avoidance and tax evasion
The ATO workers were among nearly 57,000 people who were duped into claiming fake GST refunds, while Kuwait signed a double taxation treaty with the UAE
However, ICAP may not provide the legal certainty of an APA and tax authorities will have limited capacity, experts argue
Gift this article