Deloitte’s TP controversy guide: Prevention and resolution

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

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 & shared bottom lb ros

More from across our site

The South Africa vs SC ruling may embolden the tax authority to take a more aggressive approach to TP assessments, an adviser tells ITR
Indirect tax professionals now rate compliance as a bigger obstacle than technology and automation; in other news, Italy approved a VAT cut on art sales
AI-powered tax agents are likely to be the next big development in tax technology, says Russell Gammon of Tax Systems
FTI Consulting’s EMEA head of employment tax and reward tells ITR about celebrating diversity in the profession, his love of musicals, and what makes tax cool
Canadian Prime Minister Mark Carney and US President Donald Trump have agreed that the countries will look to conclude a deal by July 21, 2025
The firm’s lack of transparency regarding its tax leaks scandal should see the ban extended beyond June 30, senators Deborah O’Neill and Barbara Pocock tell ITR
Despite posing significant administrative hurdles, digital services taxes remain ‘the best way forward’ for emerging economies, says Neil Kelley, COO of Ascoria
A ‘joint understanding’ among G7 countries that ‘defends American interests’ is set to be announced, Scott Bessent claimed
The ‘big four’ firm’s inaugural annual report unveiled a sharp drop in profits for 2024; in other news, Baker McKenzie and Perkins Coie expanded their US tax benches
Representatives from the two countries focused on TP as they met this week to evaluate progress under a previously signed agreement – it is understood
Gift this article