Deloitte TP Controversy Guide 2025
Navigating rising transfer pricing disputes and evolving tax challenges in 2025
Shaun Austin and Alexander Duric of Deloitte UK introduce this year’s TP Controversy Guide, offering expert insights into global mutual agreement procedures, litigation trends, and sector-specific transfer pricing issues
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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 -
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 DeloitteAaron Xin Peng Wang and Sobhan Kar of Deloitte analyse recent developments in advance pricing agreements in China and India, highlighting evolving frameworks and implications for multinational enterprises managing transfer pricing risks
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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 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 DeloitteMultinational taxpayers are facing a growing compliance burden, say Vrajesh Dutia and Gregoire de Vogüé of Deloitte, as they highlight notable transfer pricing rulings concerning ranges, intragroup services, and loss-making entities
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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 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
Deloitte TP Controversy Guide Archive
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Sponsored by DeloitteITR has collaborated with Deloitte TP experts from around the globe to examine the latest controversies in this ever-changing aspect of the tax landscape.
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Sponsored by DeloitteFroukje Frerichs, Stefano Lavore, and Nicola Lostumbo of Deloitte provide a guide to the most common tax authority challenges in the business restructuring context and present a three-pronged approach to mitigating this risk.
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Sponsored by DeloitteVrajesh Dutia of Deloitte India and Jennifer Breeze of Deloitte UK assess the complex arm’s-length decisions that global businesses had to make during the COVID-19 pandemic, and the various responses from international tax authorities.
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Sponsored by DeloitteAriel Krinshpun and James Mahon, III of Deloitte US and George Galumov of Deloitte Switzerland analyse two areas of intercompany financing arrangements as transactions come under increasing scrutiny from tax authorities.
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Sponsored by DeloitteAaron Wang of Deloitte China and Iva Georgijew of Deloitte Poland set out the key questions when limited risk and low-risk distributors incur losses, and consider the challenges presented in several common scenarios.
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Sponsored by DeloitteEdward Morris of Deloitte UK and Sobhan Kar of Deloitte India question whether the adage that mutual agreement procedures work, but too slowly, is still correct.
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Sponsored by DeloitteGeoff Gill of Deloitte Australia and Andrew Skipsey of Deloitte UK analyse the use of profit split transfer pricing methods in the rapidly evolving banking and commodity trading businesses.
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Sponsored by DeloitteSimón Somohano and Francisco Díaz of Deloitte S-LATAM explain the changes for maquiladoras after the repeal of advance pricing agreements as a compliance option and the implications for Mexico’s competitiveness as a manufacturing location.
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Sponsored by DeloitteKirsti Longley of Deloitte Tax LLP and Carlos Serrano Palacio of Deloitte Spain explain the benefits of advance pricing agreements in managing transfer pricing exposure, and the pros and cons of unilateral and bilateral advance pricing agreements.
