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Transfer Pricing
More sophisticated use of technology, heightened TP scrutiny and stricter filing requirements are making South African Revenue Service audits a formidable challenge
November 12, 2025
features sponsored features special focus local insights
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The Deloitte network of member firms in the Americas deploys the applicable local and regional teams quickly. Deloitte's Americas tax controversy teams consist of more 280 professionals with offices in 130 locations through a network of member firms. -
Tetyana Berezhna
Sponsored Features
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Sponsored by CMSTaxpayers may have to refine their approach in staving off tax controversy. A podcast held by ITR in collaboration with CMS explains why audits and tax litigation may never be the same
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Sponsored by insightsoftwareJoin Deloitte and insightsoftware on November 4 for a free ITR webinar exploring how operational transfer pricing transformation can streamline data, improve compliance, and integrate business and financial processes across multinational organisations
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Sponsored by DeloitteHow can tax leaders enhance process ownership, manage distributed teams, and balance talent with technology? James Paul of Deloitte UK presents valuable insights from the Tax Transformation Trends 2025 report
Special Focus
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Sponsored by DDTC ConsultingDavid Hamzah Damian of DDTC Consulting examines recent procedural changes in Indonesia’s tax disputes process and the Supreme Court’s stance on tax evidence, highlighting key implications for taxpayers facing audits, objections, and appeals
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Sponsored by DeloitteEddie Morris, Josep Serrano Torres, and Jen Breeze of Deloitte compare transfer pricing controversies in the pharmaceutical and automotive sectors, highlighting how DEMPE functions, regulation, and intangibles drive both common themes and sector-specific challenges
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Sponsored by DeloitteCarlos 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
Local Insights
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Sponsored by GNV ConsultingFabian Abi Cakra and Aditya Nugroho of GNV Consulting say a new regulation underlines the Directorate General of Taxes’ shift towards real-time, data-based compliance enforcement
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Sponsored by MDDPMagdalena Marciniak and Magdalena Dymkowska of MDDP explain how Poland is sharpening its transfer pricing audits, considering periodic reviews for the largest taxpayers, and increasing the use of tools designed to foster certainty
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Sponsored by Spanish VAT ServicesFernando Matesanz of Spanish VAT Services examines how the opinion delivered in case C-515/24 addresses whether Spain could limit VAT deduction rights at the moment of its EU accession under the standstill clause
