Transfer pricing trends for 2025: looking back to look ahead

January 30 2025

2025 growth business. wooden block with 2024 change to 2025, Set up objective target business cost and budget planning for new year concept

From pillar two and amount B to Apple’s headline EU Commission dispute, Martin Bonner and Yiwen Ping of Kreston Global argue that 2024’s key TP developments will inform 2025

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

Transfer Pricing Global Kreston Global Feature

Martin Bonner

Partner Kreston Global

Martin is chair of the Kreston Global transfer pricing (TP) group and a partner and tax adviser at AREA Bollenberger in Austria, specialising in TP. With a focus on customer-oriented solutions and a commitment to providing comprehensive advice, including implementation support, he offers innovative and end-to-end solutions in TP, customs law (exceptional procedures and optimisations), VAT, and tax technology.

Yiwen Ping

Partner Kreston Global

Yiwen Ping is a partner at Zhonghui China. With more than 15 years of experience, she is a tax consultant with a focus on transfer pricing (TP), and is an expert in contemporaneous documentation, related party declarations, CbCr, multinational corporation profit monitoring, TP planning, value chain transformation, TP dispute coordination and related services.

more across site & shared bottom lb ros

More from across our site

Direct Tax

Private client asset management

A taxing week: Tax firms can’t afford to ignore increased private client demand

As ITR data reveals that 2025 saw more than double the amount of private client hires than 2024, it seems firms are jostling for position

Sam Sholli, May 29 2026

Direct Tax

This week in tax: Amazon’s UK tax bill tops £1bn

The US multinational paid 20% more tax in 2025 than 2024, it said; in other news, more than 25,000 HMRC staff have been upskilled on AI

Tom Baker, May 29 2026

Direct Tax

Photo merge template.png

Pillar two presenting ‘culture change’ challenges in Asia-Pacific: KPMG policy leaders

Belt and Road Initiative countries face tax incentive conundrums due to pillar two, but relatively few countries would seek to scrap the project, ITR has heard

Sam Sholli, May 28 2026

Direct Tax

Gulf Cooperation Council GCC

The future of tax incentives in the GCC after pillar two

Hany Elnaggar examines how the OECD’s global minimum tax is reshaping the GCC’s investment incentive landscape, shifting the region from rate-based competition toward substance-driven economic positioning

Hany Elnaggar, May 27 2026

Direct Tax

Photo merge template.png

Charles Russell Speechlys adds five-strong private client team in Asia

The acquisition of a two-partner practice from Stephenson Harwood means that Charles Russell Speechlys has the largest private client team in Asia, the firm claimed

Sam Sholli, May 26 2026

Direct Tax

EY US bans overseas working on personal time due to tax risks

Complex and constantly shifting rules on global mobility mean ‘the risk is too great’ for staff to work abroad on personal time, EY’s Maureen Flood tells ITR

Sam Sholli, May 25 2026

Direct Tax

Audit And Fraud Investigation. Auditor Using Magnifying Glass

A taxing week: Waiving pillar two filing penalties a welcome yet sobering move

While it’s great that the OECD is alive to multinationals’ fears of being caught in a compliance trap, the ‘common understanding’ illustrates a worrying lack of readiness

Tom Baker, May 22 2026

Direct Tax

This week in tax: Tax partner headcount at large firms nearly doubles in 20 years

Rising demand for specialist expertise has fuelled the growth in tax partner headcounts, Cain Dwyer found; in other news, Switzerland has been urged to reconsider pillar two

Tom Baker, May 22 2026

Transfer Pricing

G7 flags

G7 backs pillar two SbS deal, opens pillar one dialogue

An OECD report on the taxation of the digital economy is expected by the end of 2026, according to the group of nations

Sam Sholli, May 21 2026

Direct Tax

Super yacht

How family offices are institutionalising the ownership of trophy assets

Trophy assets are evolving from personal indulgences to structured investments, prompting family offices to prioritise tax efficiency, governance discipline, and cross-border compliance

Jacopo Crivellaro, May 21 2026