Expert Analysis

MNEs are increasingly using algorithmic tools in TP. Sahasranshu Dash argues that data ethics should therefore plug directly into the TP design process

New French legislation should create a more consistent legal environment for taxing gains from management packages, say Bruno Knadjian and Sylvain Piémont of Herbert Smith Freehills Kramer

AI-powered tax agents are likely to be the next big development in tax technology, says Russell Gammon of Tax Systems

Transfer pricing (TP) controversies have arisen in all countries. Deloitte’s Eric Lesprit, Sanjay Kumar and Joseph Tobin focus on recent TP controversy developments in three: France, India, and the US.

Are transfer pricing controversy cases on the rise because of the OECD’s BEPS initiative or local country legislation? Deloitte’s Stan Hales and John Henshall explore the dynamic globally.

Mutual agreement procedures (MAPs) are becoming increasingly popular in the settlement of TP controversy. As double taxation fears abound for multinationals, Deloitte’s Edward Morris discusses the importance of a well-functioning MAP process.

Vanesa Lanciotti of Deloitte Chile explores how recent reforms – including new advance pricing agreement rules, enhanced audit priorities, and disclosure requirements – are reshaping transfer pricing practice and compliance for multinationals operating in Chile

Senior Deloitte tax practitioners examine Mexico’s evolving approach to the OECD’s amount B and summarise the transfer pricing landscape in Guatemala, Panama, Honduras, and Costa Rica

Senior Deloitte tax practitioners report that transfer pricing audits are homing in on intercompany services in Argentina, Uruguay, Colombia, Peru, Ecuador, and Venezuela, and emphasise the need for early taxpayer preparation

Marek Kończak and Tomasz Janik of MDDP say Poland’s draft amendment to the Corporate Income Tax Act addresses two key CJEU rulings but leaves open questions on scope, timing, and safeguards

Renata Colafêmina and Rafaela Calçada Cruz of Machado Associados examine full non-cumulative taxation under Brazil’s new IBS/CBS regime, the current consumption system’s credits restrictions, and the challenges of the new tax model

Edouard Authamayou of Deloitte Luxembourg examines a tribunal ruling on hidden contributions and profit distributions that highlights the importance of robust evidence supporting the arm’s-length principle in intragroup financing arrangements and interest rate waivers