Expert Analysis

Singapore has been increasing its focus on transfer pricing, explain Geoffrey K Soh, Felicia Chia and Jingyi Lee of KPMG, with yearly revisions of the TP guidelines as well as the adoption of country-by-country reporting requirements. Recently, there has been a greater-than-ever push to ensure that taxpayers’ profitability is consistent with the economic activities conducted and value generated.

Over the past year, the Australian transfer pricing (TP) landscape has continued to evolve. There is new legislation and the Australian Taxation Office (ATO) is continuing to prioritise TP as a key area, write Tim Keeling, Jay Mankad and Jennifer Goldkopf of KPMG.

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.

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