Expert Analysis

Vietnam’s regulatory changes have required an increasing number of taxpayers having to be aware of the transfer pricing rules, explain Hoang Thuy Duong, Tran Thi Thuy Ha and Sandra Liston of KPMG. However, inconsistencies in the interpretation has led to substantial efforts by the tax authority to clarify the rules.

The New Zealand transfer pricing landscape has changed rapidly over the past year, explain Kim Jarrett, Kyle Finnerty and Nadia Fediaeva of KPMG. With new BEPS legislation enacted, increased tax enforcement efforts, the Inland Revenue restructuring and a new government promising an increase in spending on tax enforcement, what more could happen in a year?

Transfer pricing is on the radar again in the Philippines, reports Maria Carmela Peralta of KPMG. It’s too early to tell whether the lengthy discussions taking place will bear fruit and the Philippines will have something other to show than its 2013 TP regulations, which the Philippine Bureau of Internal Revenue (BIR) is perceived to have overlooked.

Taxpayers may have to refine their approach in staving off tax controversy. A podcast held by ITR in collaboration with CMS explains why audits and tax litigation may never be the same

Join Deloitte and insightsoftware on November 4 for a free ITR webinar exploring how operational transfer pricing transformation can streamline data, improve compliance, and integrate business and financial processes across multinational organisations

How can tax leaders enhance process ownership, manage distributed teams, and balance talent with technology? James Paul of Deloitte UK presents valuable insights from the Tax Transformation Trends 2025 report

David Hamzah Damian of DDTC Consulting examines recent procedural changes in Indonesia’s tax disputes process and the Supreme Court’s stance on tax evidence, highlighting key implications for taxpayers facing audits, objections, and appeals

Eddie Morris, Josep Serrano Torres, and Jen Breeze of Deloitte compare transfer pricing controversies in the pharmaceutical and automotive sectors, highlighting how DEMPE functions, regulation, and intangibles drive both common themes and sector-specific challenges

Carlos Serrano Palacio and Szymon Wlazlowski of Deloitte examine how transfer pricing complexities arise in special purpose vehicle investments and outline key considerations in navigating their unique risk, substance, and valuation challenges

Bernardo Mesquita of Morais Leitão, Galvão Teles, Soares da Silva & Associados examines how AI can enhance tax administration efficiency while raising significant transparency, accountability, and taxpayer-rights concerns that governments must address

Tiago Marreiros Moreira, Rita Simão Luís, and Nadine Gomes of VdA analyse how recent EU VAT and energy tax developments shape electric mobility, highlighting opportunities from CJEU rulings and challenges of multi-layered tax frameworks

Federico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente explain how accurate comparable selection is essential in transfer pricing benchmarking, highlighting OECD approaches, practical screening steps, and lessons from recent Italian case law