ITR has partnered with global TP leaders from Deloitte to discuss transfer pricing controversy around the globe, and to share advice on how to navigate an increasingly uncertain and risky TP landscape.
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Sponsored by DeloitteIn collaboration with tax experts from Deloitte member firms around the world, ITR’s Transfer Pricing Controversy guide provides strategies to help avoid and resolve disputes as tax authorities resume pre-pandemic levels of activity.
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Sponsored by DeloitteIncreased transfer pricing documentation requirements are not reducing the number of disputes. Jennifer Breeze, Chris Ferguson, and Simón Somohano of Deloitte offer regional perspectives on the issue and explain what businesses may be able to do to prevent escalation.
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Sponsored by DeloitteRather than simplifying and standardising international tax, the OECD BEPS recommendations have led to a complex landscape. Vrajesh Dutia and Eric Lesprit of Deloitte analyse the application of the guidance across several high-profile jurisdictions.
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Sponsored by DeloitteSobhan Kar of Deloitte India and Aaron Wang and Michael Sun of Deloitte China evaluate the use of advance pricing agreements in their jurisdictions, and consider how both countries’ programmes are likely to evolve.
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Sponsored by DeloitteShaun Austin, Karishma Phatarphekar, and Jack Smith of Deloitte consider three factors that are driving changes to business models and set out best practice for transfer pricing professionals in handling the tax implications.
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Sponsored by DeloitteEddie Morris and Markus Kircher of Deloitte consider the common causes of transfer pricing (TP) disputes in the automotive and media sectors.
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Sponsored by DeloitteIncreased transparency requirements have pushed the management of tax risk higher up companies’ agendas. Juan Ignacio de Molina, Yoshihiro Adachi, and Carlos Serrano of Deloitte explain how corporate governance and cooperative programmes can help.
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Sponsored by DeloitteSophie Brown and Sarah Blakelock of Deloitte highlight the lessons to be learnt from transfer pricing disputes and case law as tax authorities increasingly pursue data interrogation, source data, and access to emails.
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Sponsored by DeloitteEddie Morris of Deloitte considers the limited evidence available on the use of the arbitration clause of mutual agreement procedure articles to resolve transfer pricing disputes, and pinpoints areas for improvement.
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In collaboration with global TP leaders from Deloitte, ITR brings you expert knowledge and solutions to the opportunities and threats that the TP controversy world of today presents.
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Sponsored by Deloitte Transfer Pricing GlobalEric Lesprit and John Breen of Deloitte look to the future of transfer pricing dispute resolution, including the proposals in the OECD’s pillar one digital tax blueprint, multilateral negotiations and joint audits.
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Sponsored by Deloitte Transfer Pricing GlobalEdward Morris and Jamie Hawes of Deloitte discuss how the resolution of controversy has changed with the introduction of a more efficient system to handle MAPs and APAs.
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Sponsored by Deloitte Transfer Pricing GlobalAlison Lobb and Howard Osawa of Deloitte explore potential areas of controversy arising from the G20/OECD’s pillar one and pillar two project and considerations to manage disputes and potential double taxation.
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Sponsored by Deloitte Transfer Pricing GlobalKerwin Chung and Carlo Llanes Navarro of Deloitte provide an insight into ITR’s transfer pricing controversy guide, produced in collaboration with global transfer pricing experts from Deloitte.