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 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 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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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 TPC GroupCarlos Vargas Alencastre of TPC Group provides analysis of Google’s strategy in relation to transfer pricing.
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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 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.
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Sponsored by Tax Partner AG, Taxand SwitzerlandHendrik Blankenstein and Caterina Colling Russo of Tax Partner evaluate the transfer pricing challenges that the COVID-19 pandemic has brought for multinational enterprises.
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Sponsored by Bennett ThrasherBenjamin Miller and Abbas Raza of Bennett Thrasher outline a step-by-step framework for value chain analyses that will assist tax and transfer pricing professionals in evaluating risks, identifying opportunities and preparing appropriate master file documentation.
