Expert Analysis

The European General Court (EGC) has ruled against the European Commission in the Apple case, meaning the US company does not have to repay €13 billion ($14.8 billion) in state aid benefits it received in Ireland.

Businesses are finding it difficult to deal with transfer pricing (TP) data and how to apply an arm’s-length analysis in a global economy that looked completely different just six months ago.

As countries provide incentives to attract foreign investment, the OECD may have to readdress the BEPS framework in the post-COVID future.

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

Dinko Dinev of Deloitte Luxembourg explores how automation is transforming debt pricing studies in transfer pricing, highlighting efficiency gains but also analytical risks that can arise if technology is misapplied

Jakub Warnieło and Aleksandra Bulaszewska of MDDP outline the key takeaways from a report on Polish tax trends, covering tax inspections, verification activities, tax proceedings, and the business viewpoint

Corina Mîndoiu and Geanina Ciorâță of EY Romania explain how the country’s flat-tax consistency, digital integration, and transparent residency rules continue to attract investors, professionals, and digital nomads from around the world