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Transfer Pricing
As multinationals embed tax technology into their TP functions, a new breed of systems – built on multi-model databases – is quietly transforming intercompany pricing logic
November 6, 2025
features sponsored features special focus local insights
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The European Commission has defended its controversial 2016 Apple state aid decision after losing the case at the European General Court (EGC), but some lawyers are not anticipating an appeal. -
The European General Court (EGC) has ruled against the European Commission in the Apple case, meaning the US company does not have to repay €13 billion ($14.8 billion) in state aid benefits it received in Ireland.
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Businesses are finding it difficult to deal with transfer pricing (TP) data and how to apply an arm’s-length analysis in a global economy that looked completely different just six months ago.
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
