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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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  • Over the last couple of months, Chilean taxpayers have been subject to new transfer pricing compliance requirements, which have significantly changed their perception of the proper way to handle intercompany transactions. Roberto Carlos Rivas, Carolina Alexandres and Gabriel Bernal of PwC Chile explain how taxpayers can navigate through the changes.
  • 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.
  • Susann van der Ham and Carsten Hüning of PwC Germany discuss recent developments in tax audits practice towards transfer pricing risk assessments strategies.

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