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Expert Analysis

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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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  • Hans-Ulrich Lauermann, Justin Woodhouse and Jörg Schwerdtfeger of PwC throw light on details of the new tax transparency requirements and how affected credit institutions could approach them.
  • Historically, transfer pricing rules in Ukraine have been vague and were seldom applied by the Ukrainian tax authorities. Konstantin Karpushin, Anna Korobova and Oleksandra Tovkun of KPMG explain why taxpayers need to adopt a long-term view on their transfer pricing strategy.
  • In 2011, Russia enacted revised transfer pricing (TP) rules. However, over the last 18 months the Russian Tax Authority (RTA) has issued various letters clarifying its views on the new TP rules. Evgenia Veter, Steve Cawdron, Anuar Mukanov and Filip Vukovic of Ernst & Young have interpreted these clarifications and their potential impact for businesses as they attempt to comply with the revised legislation.

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