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Settling into the new normal world of TP controversy


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


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ITR invites tax firms, in-house teams, and tax professionals to make submissions for the 2023 ITR Tax Awards in Asia-Pacific, Europe Middle East & Africa, and the Americas.
Tax authorities and customs are failing multinationals by creating uncertainty with contradictory assessment and guidance, say in-house tax directors.
The CJEU said the General Court erred in law when it ruled that both companies benefitted from Italian state aid.
An OECD report reveals multinationals have continued to shift profits to low-tax jurisdictions, reinforcing the case for strong multilateral action in response.
The UK government announced plans to increase taxes on oil and gas profits, while the Irish government considers its next move on tax reform.
War and COVID have highlighted companies’ unpreparedness to deal with sudden geo-political changes, say TP specialists.
A source who has seen the draft law said it brings clarity on intangibles and other areas of TP including tax planning.
Tax consultants say companies must not ignore financial transactions in their TP policies as authorities, particularly in the UK, become more demanding.