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Transfer Pricing
Multinationals face rising TP scrutiny as global rules diverge. As Daniel Moalusi argues, strong, consistent documentation is now essential to minimise audit risk and protect tax positions
February 26, 2026
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  • Mark Whitehouse and Simon Wilks PwC Legal and PwC There have been a number of features of the UK tax dispute landscape over the course of the past year which are worthy of note. In the first instance, the UK's Public Accounts Committee (PAC) has taken a keen interest in tax compliance and tax avoidance. The enquiries of the PAC have included within their remit a number of important issues for large corporate groups. The PAC has summoned large corporate entities to discuss their tax affairs, including corporate groups such as Starbucks, Google and Amazon. The result of this is that this has created an environment in which many large corporate groups find their tax affairs under unusually high scrutiny.

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