Special Focus
Transfer Pricing Controversy (2nd edition)

Special Focus Archive

Transfer pricing in 2019

Deloitte Touche Tohmatsu’s global transfer pricing practice, in partnership with International Tax Review, is pleased to present the 2019 edition of the Transfer Pricing Controversy Guide, a discussion and overview of the leading issues, challenges and opportunities around transfer pricing (TP) controversy.
What the tax authorities are up to: Key audit trends globally

Public and political pressure has seen tax authorities play closer attention to transfer pricing. Deloitte’s Tony Anderson, Alex Evans, Mariusz Kazuch, Rafal Sadowski and Lian Tang He explore changes in Canada, China and Poland.
Joint audits, ICAP, and the role of risk assessment

Cross-border cooperation in transfer pricing risk assessments and audits has presented cost saving opportunities, but increased reporting obligations for MNEs. Deloitte’s Manfred Naumann and David Varley explore the experience in Germany and the US.
From best endeavours to binding arbitration: Eliminating double taxation

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.
Chicken or the egg: TP, BEPS, and local-country legislation

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.
A national perspective: TP controversy in France, India, and the US

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.
An industry perspective: Financial services, life sciences and automotives

Post-BEPS, TP controversy has affected all industries. Deloitte’s Ralf Heussner, Aydin Hayri and Juan Ignacio de Molina explore the impact on the financial services, life sciences and automotive industries.