Transfer Pricing Guide 2026
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Sponsored by Steadfast Business ConsultingMithilesh Reddy of Steadfast Business Consulting outlines the key transfer pricing compliance risks, pillar two impacts, and structuring priorities for multinational enterprises under the UAE’s new R&D tax credit regime -
Sponsored by YulchonSeveral South Korean transfer pricing cases have established clearer judicial standards emphasising robust comparability analysis and stronger functional and economic evidence. Yulchon tax partners provide practical insights for navigating the heightened requirements
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Sponsored by RSM IndonesiaIchwan Sukardi and T Qivi Hady Daholi of RSM Indonesia examine how geopolitical conflict and economic volatility are reshaping transfer pricing risk and enforcement, with a particular focus on Southeast Asia and Indonesia
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Sponsored by Tax PartnerMonika Bieri and Daniel Schönenberger of Tax Partner use a Swiss lens to examine how workforce mobility is reshaping transfer pricing models, and why the location of key decision‑makers is becoming a critical tax risk
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Sponsored by Svalner Atlas AdvisorsPatrik Sedlar and William Berntö of Svalner Atlas Advisors draw on case law to question whether the Swedish Tax Agency’s stance on recharacterising intra‑group intangible property licensing arrangements conflicts with the OECD Transfer Pricing Guidelines
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Sponsored by Skeppsbron SkattMichael Cedercrantz of Skeppsbron Skatt comments on the expected update of Chapter VII of the OECD Transfer Pricing Guidelines and the introduction of the high value-adding services concept
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Sponsored by Doane Grant ThorntonRoss Harris of Doane Grant Thornton explains how Canadian transfer pricing amendments increase recharacterisation risk and heighten the need for robust documentation and transaction design
Transfer Pricing Guide archive
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Sponsored by Skeppsbron SkattMikael Jacobsen and Henri Ahtiainen of Skeppsbron Skatt explore how several recent Swedish cases have shed light on the complex distinction between legal and economic ownership of intellectual property in transfer pricing matters
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Sponsored by YulchonWith South Korea expected to intensify its focus on multinationals’ intercompany transactions during tax audits, Yulchon tax partners analyse several transfer pricing-related rulings that could help shape strategy
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Sponsored by Tax PartnerMonika Bieri and Caterina Colling Russo of Tax Partner discuss a Swiss court ruling concerning the use of multi-year margin averaging in transfer pricing adjustments and suggest several steps that could help ensure compliance
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Sponsored by RSM IndonesiaIchwan Sukardi and T Qivi Hady Daholi of RSM Indonesia explain the clarifications provided by the latest Indonesian transfer pricing regulation, but point out that uncertainty remains around several issues
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Sponsored by Tax PartnerMonika Bieri and Daniel Schönenberger of Tax Partner AG analyse a recent Federal Administrative Court case and its implications for current transfer pricing practice in Switzerland
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Sponsored by YulchonWith South Korea expected to take a more aggressive approach to auditing, tax partners from Yulchon analyse four transfer pricing-related rulings that provide guidance for multinationals
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Sponsored by Chevez Ruiz ZamarripaOscar Campero, Yoshio Uehara, and José Luis Iglesias of Chevez Ruiz Zamarripa provide a guide to the most commonly scrutinised concepts and the documentation required by the Mexican tax authority in transfer pricing audits
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Sponsored by Ikeyi Shittu & Co.As the Nigerian government aims to boost its tax revenue, Taofeek ’Bola Shittu of Ikeyi Shittu & Co. explains how to minimise the risk of additional tax liability resulting from non-compliance with transfer pricing regulations
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Sponsored by GNV ConsultingCharles Setia Oetomo, Felic Setiawan, and Gomgom Johannsen Kevan of GNV Consulting provide a guide to Indonesia’s new transfer pricing regulation, what to expect, and how taxpayers may prepare for its application
