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Transfer Pricing
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Many years ago, I was responsible for a tax group that reported to a regional group services organisation and not to the global head of tax. A new manager, with no experience of tax, had just taken over responsibility for group services and was looking to find out what each of his new teams actually did and for simple performance metrics.
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Keith Brockman looks at how to prevent and resolve disputes just as the international tax system is changing.
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Opportunities to come to a resolution with the tax authorities are generally better the earlier they present themselves in the life-cycle of a tax dispute, says Sandy Markwick, head of the Tax Director Network (TDN) at Winmark.
Sponsored Features
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Sponsored by CMSTaxpayers 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
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Sponsored by insightsoftwareJoin 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
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Sponsored by DeloitteHow 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
Special Focus
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Sponsored by DDTC ConsultingDavid 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
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Sponsored by DeloitteEddie 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
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Sponsored by DeloitteShaun Austin and Alexander Duric of Deloitte UK introduce this year’s TP Controversy Guide, offering expert insights into global mutual agreement procedures, litigation trends, and sector-specific transfer pricing issues
Local Insights
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Sponsored by Spanish VAT ServicesFernando Matesanz of Spanish VAT Services examines how the opinion delivered in case C-515/24 addresses whether Spain could limit VAT deduction rights at the moment of its EU accession under the standstill clause
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Sponsored by Gatti Pavesi Bianchi LudoviciPaolo Ludovici and Andrea Mirabella of Gatti Pavesi Bianchi Ludovici analyse the tax authorities’ ruling on cross-border dividend withholding and the domestic capital gains exemption as applied to a Maltese trust electing corporate tax status
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Sponsored by Deloitte LuxembourgDinko Dinev of Deloitte Luxembourg explores how automation is transforming debt pricing studies in transfer pricing, highlighting efficiency gains but also analytical risks that can arise if technology is misapplied