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The impact of COVID-19 – ITR’s TP Special Focus launched

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Transfer pricing specialists share their analysis and insight in the 22nd edition of ITR’s Transfer Pricing guide.

The longer-term effects of the COVID-19 pandemic continue to make themselves known in the TP world, as companies consider how to make appropriate adjustments, and how to make comparability analysis work in this landscape. Suryani Suyanto & Associates, KPMG China, and Deloitte teams in the Philippines and Vietnam discuss.

The pandemic also accelerated the adoption of technology and sales of intangibles, with inevitable consequences for TP teams, as Baker McKenzie and Deloitte teams in Malaysia and Singapore explain.

Meanwhile, tax disputes continue with activity in some courts picking up after a lull during the height of the pandemic. Arendt & Medernach, Chevez, and GNV Consulting discuss the use of the mutual agreement procedure and advance pricing agreements to avoid, or tackle, disputes.

As Deloitte France explains, the OECD’s two-pillar global tax solution is under development following the agreement in October 2021, while LED Taxand writes about Italian case law on intercompany loans, and TaxPartner considers the deductibility of management fees in real estate funds.

Also in this guide, Deloitte Indonesia and Skeppsbron Skatt share the considerations that tax managers should bear in mind for intra-group TP transactions, DDTC examine the death of Libor in Indonesia, and Deloitte Thailanddiscusses recent TP developments in the country.

Finally, read on for an examination of country-by-country reporting in Israel by Herzog Fox & Neeman, and an interesting analysis of Google’s TP strategy by TPC Group.

We hope you enjoy reading the 22nd edition of our Transfer Pricing guide.

Click here to read all the chapters from ITR's TP Special Focus

 

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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.