Settling into the new normal world of TP controversy

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

Settling into the new normal world of TP controversy

0-editorial-as105946605.jpg

In collaboration with global TP leaders from Deloitte, ITR brings you expert knowledge and solutions to the opportunities and threats that the TP controversy world of today presents.

Click here to read Deloitte's TP Controversy Guide 2021

The Deloitte TP Controversy Guide arrives at a time when new developments, including revisions to the 2017 OECD TP Guidelines, are rapidly creating the new normal for global disputes and litigation.

As businesses across the world continue to deal with the disruption of COVID-19, which in turn may lead to tax controversies, mitigating the risk is key going forward.

More efficient systems to handle mutual agreement procedures and advance pricing agreements will continue to have a significant impact on tax controversies on a global scale. Deloitte’s recent survey, completed by TP experts from more than 55 countries, showed that APAs remain the key tool available for dispute prevention benefitting both taxpayers and tax authorities.

Tax authorities are globally increasingly focused on taxpayers’ intangibles arrangements and TP outcomes. Financial transactions continue to be another active area of TP controversy for tax authorities. COVID-19 will also have a longer-term impact on how multinational corporations operate specifically in relation to the reporting of country-by-country data.

Other themes dominating the controversy landscape are the OECD’s pillar one and pillar two project, which aims to address the complex issues arising from digital businesses, and initiatives to improve multilateral dispute resolution procedures.

At a time of acceleration in TP controversy, there are challenges that may cause concern. Deloitte’s TP controversy teams, across the globe, are well placed to assist companies through these particular challenges.

We hope that you enjoy reading the practical insights explored in the fourth edition of the TP Controversy Guide.

Click here to read Deloitte's TP Controversy Guide 2021

 

more across site & shared bottom lb ros

More from across our site

Wim Wuyts, who had been head of the specialist tax network since 2017, is moving on to a new role with WTS’s Belgian member firm
MNEs are increasingly using algorithmic tools in TP. Sahasranshu Dash argues that data ethics should therefore plug directly into the TP design process
The Institute of Chartered Accountants in England and Wales also queried whether HMRC resources could be better spent scrutinising larger entities
Grant Thornton’s Austria tax head likens his practice to an escape room, shares his football coaching ambitions, and explains why tax is cool
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2025 EMEA Tax Awards
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2025 Asia-Pacific Tax Awards
The fates of pillars one and two hang in the balance after the US successfully threw its weight around in G7 and Canadian negotiations
Rafael Tena tells ITR about the ‘crazy’ Mexican market, ditching the hourly rate, and refusing to grow his fledgling firm in an ‘unstructured way’
It should be easy for advisers to be transparent about costs, Brown Rudnick partner Matthew Sharp said in response to exclusive ITR in-house data
The sprawling legislation phases out Joe Biden-era green tax incentives for businesses; in other news, the UK will reportedly maintain its DST despite US pressure
Gift this article