Getting ahead of the next transfer pricing challenge

The guide arrives at a pivotal moment as multinationals juggle challenges thrown at them by trade frictions and increasing regulations, amid widespread economic disruption.

The idea of settling into a 'new normal' following the COVID-19 pandemic has forced tax authorities and taxpayers to respond. A number of industries are expecting additional scrutiny and detailed documentation requests to become the norm in the coming years. Businesses also fear that the application of the arm's-length principle could be altered as governments ramp up efforts to yield tax revenues.

In spite of the challenges, innovation and product development among TP professionals is at an all-time high. The use of data analytics has spearheaded efficiency when it has come to audits, while, with the help of fine-tuning, the number of mutual agreement procedures in the EU are on the rise. In Latin America, advance pricing agreements are being promoted and will subsequently raise the confidence of investors in the region.

Meanwhile, the OECD continues to lead multilateral efforts to address problematic themes such as the retrospective application of guidelines and the regulations surrounding financial transactions.

As demands and queries progressively become international, global TP controversy frameworks have strengthened. China, India and South Korea have reinforced their models over the past decade by adopting best practices, while a number of developing economies in Asia and Africa continue the process of formalisation. Four key cases from the recent past: Adecco (Denmark), Cameco (Canada), Glencore (Australia), and Philips (France), have also helped invigorate guidelines.

Across the globe, Deloitte's TP controversy teams are well placed to assist companies through their particular challenges. We hope that you enjoy reading the practical insights explored in the third edition of our Transfer Pricing: Controversy guide.

Click here to read the entire 2020 Deloitte/ITR Transfer Pricing Controversy guide

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