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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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Participants in the consultation on the UN secretary-general’s report into international tax cooperation are divided – some believe UN-led structures are the way forward, while others want to improve existing ones. Ralph Cunningham reports.
The German government unveils plans to implement pillar two, while EY is reportedly still divided over ‘Project Everest’.
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Xing Hu, partner at Hui Ye Law Firm in Shanghai, looks at the implications of the US Uyghur Forced Labor Protection Act for TP comparability analysis of China.
Karl Berlin talks to Josh White about meeting the Fair Tax standard, the changing burden of country-by-country reporting, and how windfall taxes may hit renewable energy.
Sandy Markwick, head of the Tax Director Network (TDN) at Winmark, looks at the challenges of global mobility for tax management.
Taxpayers should look beyond the headline criteria of the simplification regime to ensure that their arrangements meet the arm’s-length standard, say Alejandro Ces and Mark Seddon of the EY New Zealand transfer pricing team.
In a recent webinar hosted by law firms Greenberg Traurig and Clayton Utz, officials at the IRS and ATO outlined their visions for 2023.