Deloitte TP controversy guide

Tax authorities are tightening their focus on intercompany loans, guarantees, and cash pooling. George Galumov and Immacolata Abbamondi of Deloitte explain how multinational enterprises can mitigate risks in financial transactions transfer pricing

Carlos Serrano Palacio and Szymon Wlazlowski of Deloitte examine how transfer pricing complexities arise in special purpose vehicle investments and outline key considerations in navigating their unique risk, substance, and valuation challenges

Christine Ramsay and Takuma McNie of Deloitte explain how treating transfer pricing documentation as a risk management asset could help tax functions manage controversy, strengthen tax positions, and optimise costs