Expert Analysis

As explained by Cheng Chi, Rafael Triginelli Miraglia and Choon Beng Teoh of KPMG, transfer pricing continues to be one of the Chinese State Administration of Taxation’s key areas of focus, as new policies and methodologies are being examined post-BEPS to strengthen the SAT’s monitoring of multinational enterprises’ TP

Transfer pricing rules were introduced in Sri Lanka in 2006 and became enforceable from 2008, writes Shamila Jayasekara of KPMG. The revenue authorities did not administratively enforce the rules, giving time for taxpayers to conform to requirements.

It has been more than three years since the framework of the transfer pricing law was first drafted and approved by the Cabinet of Thailand in May 2015, write Benjamas Kullakattimas, Abhisit Pinmaneekul and Chollatip Santitorn of KPMG.

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