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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 Partner AGMonika 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
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Sponsored by DDTC ConsultingTami Putri Pungkasan and Yurike Yuki of DDTC Consulting say an Indonesian transfer pricing update recognises the prevention of double taxation as a purpose and not merely as a means to prevent tax avoidance
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Sponsored by Skeppsbron SkattIngrid Faxing and Henri Ahtiainen of Skeppsbron Skatt analyse a proposal to incorporate the OECD Transfer Pricing Guidelines into EU law and question whether it will become a reality after several objections
Transfer Pricing Guide archive
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Sponsored by Tax Partner AGCaterina Colling Russo and Monika Bieri of Tax Partner explain the key issues as tax authorities focus on the potential for MNEs to benefit from profit shifting through the transfer and licensing of intangibles.
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Sponsored by Sołtysiński Kawecki & SzlęzakWojciech Węgrzyn of Sołtysiński Kawecki & Szlęzak explains why there is a growing interest in the various transfer pricing aspects of M&A and what the involved parties need to know.
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Sponsored by DDTC ConsultingVeronica Kusumawardani and Cindy Kikhonia F of DDTC Consulting report that anti-avoidance measures have been introduced in Indonesia despite parliamentary concerns over their impact on investment in the country.
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Sponsored by Jáuregui y Del ValleIsadora Thurm of Jáuregui y Del Valle breaks down Brazil’s tax policy overhaul as the country seeks to match international TP standards.
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Sponsored by Skeppsbron SkattMichael Cedercrantz and Ingrid Faxing of Skeppsbron Skatt explain why enhanced reporting requirements and public awareness regarding ESG presents risks but also opportunities for MNEs navigating an increasingly complex tax terrain.
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Sponsored by Chevez Ruiz ZamarripaOscar Campero, Yoshio Uehara and José Luis Iglesias of Chevez Ruiz Zamarripa report that maquila companies must navigate new transfer pricing waters after the withdrawal of their option to submit advance pricing agreements.
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Sponsored by GNV ConsultingCharles Setia Oetomo, Felic Setiawan and Wirawan Sasongko of GNV Consulting Services outline the development of Indonesia’s transfer pricing landscape, uncertainty surrounding secondary transfer pricing adjustments and how taxpayers may address it.
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ITR has garnered the insight of tax experts from firms around the globe to understand the complexities of the transfer pricing landscape.
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Sponsored by DeloitteDaniel Alexander Laoh and Manmeet Vij of Deloitte explain why digitalisation is increasingly key for tax leaders as they face increasing compliance requirements and a global push for tax transparency.
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Sponsored by Arendt & MedernachViktoria Dimitrova and Alain Goebel of Arendt & Medernach reflect on the conclusions that may be drawn from the FIAT state aid case for TP purposes.
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Transfer pricing specialists share their analysis and insight in the 22nd edition of ITR’s Transfer Pricing guide.
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Sponsored by DeloitteJulien Pellefigue of Deloitte Société d’Avocats explains the importance of pillars one and two and the impact on transfer pricing.
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Sponsored by Baker McKenzie MexicoGustavo Sanchez-Gonzalez, Armando Cabrera-Nolasco and Katia Huezo of Baker McKenzie describe the key concepts surrounding marketing intangibles and the way tax regulations and tax authorities in the region are tackling these issues.
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Sponsored by TPC GroupCarlos Vargas Alencastre of TPC Group provides analysis of Google’s strategy in relation to transfer pricing.
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Sponsored by DeloitteCarlo L Navarro and Sujay Thakkar of Deloitte explore how new-age technologies such as blockchain and the metaverse may reshape value chains.
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Sponsored by DDTC ConsultingRomi Irawan and Muhammad Putrawal Utama of DDTC explain various aspects of the Libor transition, its implication for transfer pricing and the key takeaways for transition planning from Indonesia’s perspective.
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Sponsored by DeloitteDinh Mai Hanh, Tat Hong and Supratik Mukherjee of Deloitte Tax Vietnam discuss some of the transfer pricing challenges that could be faced by entities in Vietnam that are a part of a multinational enterprise group, in the wake of COVID-19.
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Sponsored by DeloitteCarlo L Navarro, Vrushang Sheth and Rishi Mehrotra of Deloitte discuss why it has become even more critical for taxpayers to be prepared to explain and defend their TP positions.
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Sponsored by Suryani Suyanto & AssociatesSusy Suryani of Suryani Suyanto & Associates discusses the transfer pricing challenges and issues faced by multinational corporations in relation to comparability analysis.
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Sponsored by Tax Partner AG, Taxand SwitzerlandMonika Bieri and Caterina Colling-Russo of Tax Partner AG Switzerland discuss a case of the Federal Administrative Court regarding the deductibility of management fees in an international real estate fund setup to be judged soon by the Swiss Federal Supreme Court.
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Sponsored by GNV ConsultingRecent changes to Indonesia’s tax laws give taxpayers cause for optimism, as Charles Oetomo, Felic Setiawan and Wirawan Sasongko of GNV Consulting explain.
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Sponsored by DeloitteSubhabrata Dasgupta and Jimit Parikh of Deloitte Malaysia explain why taking note of intangible actions will make for better transfer pricing analysis.
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Sponsored by KPMG ChinaXiaoyue Wang and Choon Beng Teoh of KPMG China explain the complexities of performing year-end transfer pricing adjustments in China, including their impact on customs and indirect taxes, and the possible longer-term solutions taxpayers can consider in managing their TP arrangements.
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Sponsored by LED TaxandStefano Bognandi and Elena Baron of LED Taxand considers recent Italian case law and compliance with the arm’s-length principle.
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Sponsored by Chevez Ruiz ZamarripaRicardo Rendón and Rafael Ramírez-Moreno of Chevez Ruiz Zamarripa discuss the issues arising from the application of the MAP.
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Sponsored by Arendt & MedernachAlain Goebel, Danny Beeton and Benjamin Tempelaere of Arendt & Medernach explain the use of bilateral/multilateral APAs and MAPs and consider how they can be used by taxpayers during times of uncertainty.
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Sponsored by DeloitteWhile clarity on the application of Thailand’s TP laws has now largely been achieved with the issuance of supporting regulations in the past year, a few pieces of the jigsaw still remain before the picture is complete, explains Stuart Simons of Deloitte Thailand.
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Sponsored by DeloitteSandra Suhenda, Beatrice Simamora and Kartika Sukmatullahi Hasanah of Deloitte Indonesia take a practical look at what Indonesian taxpayers can expect on transfer pricing issues pertaining to profit linked intragroup service and how they can prepare to navigate through these challenges.
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Sponsored by Skeppsbron SkattMikael Jacobsen, Malin Andersson and Janina Hägg of Skeppsbron Skatt explain why intra-group agreements in Sweden can be problematic.
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Transfer pricing specialists from around the world come together to share solutions and knowledge in ITR’s 21st edition of the Transfer Pricing guide.
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Sponsored by TPC GroupCarlos Vargas Alencastre and Johana Araujo Fuertes of TPC Group provide an overview of how businesses operating in Latin America need to meet transfer pricing documentation requirements.
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Sponsored by EY RussiaEvgenia Veter of EY outlines the Federal Tax Service’s guidelines on taxing intra-group services in Russia and considers its potential impact for businesses and taxpayers.
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Sponsored by GNV ConsultingCharles Setia Oetomo and Felic Setiawan of GNV Consulting Services explore the effect of COVID-19 on the growth of the digital economy and transfer pricing in Indonesia.
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Sponsored by YulchonYun Heui Cho, Yong Whan Choi, Kyu Dong Kim and Jeremy Everett of Yulchon consider the possibility of pursuing a mutual agreement procedure, a domestic appeal, or both simultaneously, in the event of transfer pricing disputes in South Korea.
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Sponsored by Crowe Valente/Valente Associati GEB PartnersFederico Vincenti and Alessandro Valente of Crowe Valente/Valente Associati GEB Partners provide an update on an effective and commonly used dispute resolution instrument, the mutual agreement procedure.
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Sponsored by DS AvocatsCyril Maucour, Stéphane Gasne and Jessica Benchetrit of DS Avocats consider how the BEPS project implementation by the Multilateral Instrument exacerbates tax and employment problems related to the international mobility of employees.