Expert Analysis

A new ‘profit diversion compliance facility’ (PDCF) announced by the UK tax authority aims to encourage companies to bring their transfer pricing (TP) arrangements in line with HMRC’s interpretation of the arm’s-length principle, writes Ben Regan, transfer pricing partner at EY.

The rate of change in the tax regulatory environment in recent years has been rapid, arguably more so than at any other time in recent history. Heads of tax are competing with colleagues in other functions for a share of finite budgets. The challenge is to show value for money, writes Sandy Markwick, head of the Tax Director Network at Winmark.

For all companies that sell to US consumers without a physical presence in states, 2018’s Wayfair decision was a bolt from the blue. But the work of complying with ‘economic nexus’ rules in every taxing jurisdiction will be an ongoing project, not a one-off effort.

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

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

Paolo Ludovici and Andrea Mirabella of Gatti Pavesi Bianchi Ludovici analyse the tax authorities’ ruling on cross-border dividend withholding and the domestic capital gains exemption as applied to a Maltese trust electing corporate tax status

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