Deloitte TP Controversy Guide 2026
Rethinking TP controversy in a time of transformation: certainty, simplification, and scrutiny
Carlos Serrano Palacio, Inka Traeger, and Bernardo Misle of Deloitte introduce the 2026 Deloitte TP Controversy Guide, highlighting the transfer pricing developments, dispute prevention tools, and audit trends reshaping controversy management worldwide
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Sponsored by DeloitteJamie Bedford, Henning Scheibe, and Miller Williams Jr. of Deloitte examine how US tax law changes are encouraging multinational enterprise groups to revisit US-centred intellectual property and operating models, and how European tax authorities are responding -
Sponsored by DeloitteAlexander Duric and Rachel Ney of Deloitte explain how the OECD’s updated mutual agreement procedure manual clarifies best practices for dispute resolution and may help businesses achieve greater tax certainty
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Sponsored by DeloitteImmacolata Abbamondi, Pedro Angel Villalba, and Bianca Bagnoli of Deloitte analyse how digitalisation, asset-light models, and integrated business functions are reshaping transfer pricing, from management fees and central services to AI-driven intangibles
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Sponsored by DeloitteKevin Norton and Alison Ambrose of Deloitte analyse how evolving OECD guidance, remote working, and increasingly sophisticated tax authority scrutiny are reshaping permanent establishment and transfer pricing risk – and how MNEs should respond
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Sponsored by DeloitteNew battle lines are being drawn in tax audits and litigation concerning implicit support. Tânia Rodrigues and Pablo Gil Diez De Leon of Deloitte examine how European courts and tax authorities are addressing the issue
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Sponsored by DeloitteKerwin Chung of Deloitte Tax LLP (United States) explains how IRS Notice 2025-04 could shape US adoption of amount B and simplify transfer pricing compliance for qualifying transactions
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Sponsored by DeloitteEric Linge, Vrajesh Dutia, and Ewan Kemsley of Deloitte challenge the routine use of interquartile ranges in transfer pricing, arguing that broader statistical approaches can produce more robust comparability analyses
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Sponsored by DeloitteSenior Deloitte tax practitioners examine how Mexico, Colombia, Peru, Brazil, and Chile are responding to rising transfer pricing disputes through tougher audits, evolving OECD-aligned frameworks, and growing use of APAs and MAPs
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Sponsored by DeloitteAs tax administrations adopt new IT systems and solutions for transfer pricing audits, Conrad Marburg, Takuma McNie, and Eric Lesprit of Deloitte say groups should prepare for new exposures and different forms of cooperation
Deloitte TP Controversy Guide Archive
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Sponsored by DeloitteEddie 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
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Sponsored by DeloitteHelen Cousineau, Nicola Lostumbo, and Pablo Renieblas of Deloitte examine how companies can manage tariff impacts on supply chains through transfer pricing and customs valuation, highlighting common challenges and strategies for mitigating related risks
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Sponsored by DeloitteKerwin Chung of Deloitte explains how the latest statistics on the Advance Pricing and Mutual Agreement Program show increased certainty and relief from double taxation for multinational companies
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Sponsored by DeloitteCarlos 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
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Sponsored by DeloitteChristine Ramsay and Takuma McNie of Deloitte explain how treating transfer pricing documentation as a risk management asset could help tax functions manage controversy, strengthen tax positions, and optimise costs
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Sponsored by DeloitteTax authorities are tightening their focus on intercompany loans, guarantees, and cash pooling. George Galumov and Immacolata Abbamondi of Deloitte explain how multinational enterprises can mitigate risks in financial transactions transfer pricing
