TP risk determination: Transparency and mutuality

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

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

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


TP risk determination: Transparency and mutuality

Transparency and mutuality

This month, Keith Brockman, global tax director at Mars, lecturer and author of the Strategizing Multinational Tax Risks blog, runs the rule over issues of transfer pricing risk determination, focusing on transparency and the benefits of increased levels of authority reciprocity.

Unlock this content.

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

To unlock this content:

Request Access or Login
more across site & shared bottom lb ros

More from across our site

As tax authorities embrace AI and governments weigh pillar two reforms, Latin America is developing a more connected and internationally focused tax agenda
Advisers with pre-existing corporation tax or self-assessment accounts must now register or risk enforcement action from HMRC
India's tax authorities are increasingly scrutinising the rationale behind cross-border structures
Sharmila Sanmugam's move from industry to WTS UK offers an early glimpse into how the fledgling firm hopes to compete with larger rivals
Historical claims involving KPMG Australia's tax practice have surfaced as the firm battles a separate parliamentary inquiry into its handling of whistleblowers
While AI is revolutionising tax work, it is also reshaping clients’ willingness to pay for advice and their perception of the value generated by tax advisers
From Dhruva Advisors to Svalner Atlas, Ryan is growing fast. Tom Shave discusses consolidation, competition, and tax’s private equity debate
Awards
ITR is delighted to reveal the shortlisted nominees for the Middle East Tax Awards
The UK has confirmed its approach to the OECD’s side-by-side deal, but US-parented groups may find pillar two compliance remains far from straightforward
Fragmented pillar two taxation and increased use of AI by tax authorities have left clients fearful of heightened disputes exposure
Gift this article