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.
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Sponsored by Deloitte Transfer Pricing GlobalShaun Austin, Richard Schmidtke and Aparna Rao of Deloitte discuss the challenging transfer pricing concepts of intangibles arrangements and important regulatory changes from Australia and Germany.
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Sponsored by Deloitte Transfer Pricing GlobalJuan Ignacio de Molina and Christine Ramsay of Deloitte consider the increased reliance of tax authorities on CbCR data and how the data reported in the CbCR during the COVID-19 pandemic could impede its use.
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Sponsored by Deloitte Transfer Pricing GlobalManisha Gupta, Iva Georgijew and Bhupendra Kothari of Deloitte discuss the transfer pricing risks that may arise due to business disruptions caused by COVID-19 with recommendations on how to manage those risks.
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Sponsored by Deloitte Transfer Pricing GlobalVrajesh Dutia and Ananthanarayanan R of Deloitte analyse the results of a TP controversy survey, involving TP practitioners across the globe, which seeks to gain a better understanding of the ever-evolving TP landscape.
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Sponsored by Deloitte Transfer Pricing GlobalAriel Krinshpun, James Mahon and Mo Malhotra of Deloitte explain why taxpayers may wish to review intra-group financing arrangements, and significant financing transactions in particular, for controversy risk.
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Sponsored by Deloitte Transfer Pricing GlobalMo Malhotra, Ariel Krinshpun and Ockie Olivier evaluate how the OECD guidance on financial transactions will influence an increasingly convoluted transfer pricing environment.
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Sponsored by Deloitte Transfer Pricing GlobalEric Lesprit, Mariusz Każuch and Howard Osawa look at three national case studies and consider whether the increased use of international data improves cooperation among tax administrations.
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Sponsored by Deloitte Transfer Pricing GlobalAaron Wang, Vrajesh Dutia and Chris In explain how adopting global best practices has proved to be beneficial for the development of dispute resolution procedures in China, India and South Korea.
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Sponsored by Deloitte Transfer Pricing GlobalEddie Morris, Jennifer Breeze and Janelle Sadri discuss how the growth in the number of mutual agreement procedures, coupled with fine-tuning of the process, has affected its themes of access, resolution and implementation.
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Sponsored by Deloitte Transfer Pricing GlobalKerwin Chung and Iva Georgijew assess the impact of the coronavirus pandemic on global transfer pricing and consider how the concept of the arm’s-length principle will subsequently evolve.
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Sponsored by Deloitte Transfer Pricing GlobalFred Omondi, Carlo Llanes Navarro, Anil Kumar Gupta, Lenny Saputra and Rabia Gandapur look into how developing economies across the world are embracing increasingly complex transfer pricing framework.
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Sponsored by Deloitte Transfer Pricing GlobalJari Ahonen and Juan Ignacio de Molina discuss global examples and assess the practical impact of retroactively applying the OECD Transfer Pricing Guidelines.