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 2023

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Deloitte’s TP controversy guide: Prevention and resolution

tpc2022-00.jpg

ITR has partnered with global TP leaders from Deloitte to discuss transfer pricing controversy around the globe, and to share advice on how to navigate an increasingly uncertain and risky TP landscape.

Click here to read Deloitte's TP controversy guide 2022.

The initial impact of the COVID-19 pandemic on multinational enterprises (MNEs) may have eased, but it is still far from smooth sailing for companies. Disruptions to supply chains, desperate demand for labour, and the resulting shortages of particular pieces or products have continued, while the Russia–Ukraine war and a global energy crisis add to the turbulence.

In this landscape, MNEs are finding it increasingly difficult to protect their TP strategies from the audits that tax authorities have started to resume. Mutual agreement procedures (MAPs) and advance pricing agreements (APAs) play their part in reducing uncertainty, but backlogs are affecting MNEs’ access to these options.

Meanwhile, tax authorities continue to benefit from increased access to company data, which puts MNEs under growing pressure to ensure there are no flaws in their strategies or data.

In light of this uncertainty, Deloitte’s transfer pricing experts share their advice on the following topics:

In an uncertain environment, Deloitte’s insights can help in-house tax managers at MNEs to navigate the risks and maximise any opportunities for their company that have arisen from recent changes to the TP landscape.

Click here to read Deloitte's TP controversy guide 2022.

more across site & bottom lb ros

More from across our site

PwC publishes detailed accounts of its behaviour in the tax scandal in Australia, while another tax trial looms for pop star Shakira.
The winners of the ITR Europe, Middle East, and Africa Tax Awards 2023 have been announced!
The winners of the ITR Asia-Pacific Tax Awards 2023 have been announced!
Mauro Faggion appeared cautiously optimistic as the European Commission waits to see whether all 27 member states will accept its proposal.
The global minimum rate also won’t entirely stop a race to the bottom, according to a tax director speaking at an ITR conference in London.
The country’s tax authorities are not interested in seeing transfer pricing studies any more, it was claimed at an ITR industry conference in London.
The controversial measure is being watered down after criticism from the European Central Bank.
More than 600 such requests were made in 2022, while HMRC has also bolstered its fraud service, it has been revealed.
The General Court reverses its position taken four years ago, while the UN discusses tax policy in New York.
Discussion on amount B under the first part of the OECD's two-pronged approach to international tax reform is far from over, if the latest consultation is anything go by.