Expert Analysis

Tetyana Berezhna

Indonesia completed the last step in the introduction of new transfer pricing regulations late last year, report Iwan Hoo, Aaron Brunier and Fachrur Rifqi Nugroho of KPMG. While the regulations covering the master file, local file and country-by-country reporting were issued in 2016, the implementing regulations for CbCR were not completed until late December 2017.

Transfer pricing is on the radar again in the Philippines, reports Maria Carmela Peralta of KPMG. It’s too early to tell whether the lengthy discussions taking place will bear fruit and the Philippines will have something other to show than its 2013 TP regulations, which the Philippine Bureau of Internal Revenue (BIR) is perceived to have overlooked.

Taxpayers 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

Join 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

How 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

David 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

Eddie 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

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

Fabian 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

Magdalena 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

Fernando 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