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Deloitte’s TP controversy guide: Prevention and resolution


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.

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