Transfer pricing and centralised operating models: An Australian perspective Offshore marketing hubs are becoming increasingly commonplace for Australian resource firms in Asia. Deloitte’s John Bland and Milla Ivanova discuss what factors may trigger increased regulatory scrutiny for a multinational... By John Bland & Milla Ivanova March 05 2019
Russia’s application of the CUP method An update to Russian transfer pricing regulations has seen an uptick in tax authority audits applying the comparable uncontrolled price (CUP) method. Deloitte’s Dmitry Kulakov, Alexey Sobchuk, Dmitriy Masharov, and... By Alexey Sobchuk & Anastasia Kopysova & Dmitry Kulakov & Dmitry Masharov March 05 2019
Transfer pricing energy destination markets in Southeast Asia Southeast Asia is a major energy and resource destination market, but its varied geopolitical structure gives rise to a number of unique TP challenges. By Avik Bose & See Jee Chang March 05 2019
From best endeavours to binding arbitration: Eliminating double taxation Mutual agreement procedures (MAPs) are becoming increasingly popular in the settlement of TP controversy. As double taxation fears abound for multinationals, Deloitte’s Edward Morris discusses the importance of a well-functioning... By Edward Morris February 14 2019
An industry perspective: Financial services, life sciences and automotives Post-BEPS, TP controversy has affected all industries. Deloitte’s Ralf Heussner, Aydin Hayri and Juan Ignacio de Molina explore the impact on the financial services, life sciences and automotive industries. By Ralf Heussner & Aydin Hayri & Juan Ignacio de Molina February 14 2019
What the tax authorities are up to: Key audit trends globally Public and political pressure has seen tax authorities play closer attention to transfer pricing. Deloitte’s Tony Anderson, Alex Evans, Mariusz Kazuch, Rafal Sadowski and Lian Tang He explore changes in... By Alex Evans & He Lian Tang & Mariusz Każuch & Rafał Sadowski & Tony Anderson February 14 2019
Transfer pricing in 2019 Deloitte Touche Tohmatsu’s global transfer pricing practice, in partnership with International Tax Review, is pleased to present the 2019 edition of the Transfer Pricing Controversy Guide, a discussion and overview... By Paul Riley & Shaun Austin February 14 2019
A national perspective: TP controversy in France, India, and the US Transfer pricing (TP) controversies have arisen in all countries. Deloitte’s Eric Lesprit, Sanjay Kumar and Joseph Tobin focus on recent TP controversy developments in three: France, India, and the US. By Eric Lesprit & Joseph Tobin & Sanjay Kumar February 14 2019
Chicken or the egg: TP, BEPS, and local-country legislation Are transfer pricing controversy cases on the rise because of the OECD’s BEPS initiative or local country legislation? Deloitte’s Stan Hales and John Henshall explore the dynamic globally. By John Henshall & Stanley Hales February 14 2019
Joint audits, ICAP, and the role of risk assessment Cross-border cooperation in transfer pricing risk assessments and audits has presented cost saving opportunities, but increased reporting obligations for MNEs. Deloitte’s Manfred Naumann and David Varley explore the experience in... By David Varley & Manfred Naumann February 14 2019