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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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  • Jeffrey Owens, the OECD’s former head of tax, and Mick Moore, of the University of Sussex, believe their 10 point action plan for the G8 summit this month could achieve fairer taxation of multinationals, improve tax transparency and help developing countries build up their tax capacity.
  • The increasing sophistication of transactions performed between taxpayers has raised concerns among legislators about the recurrent manipulation of the terms and conditions of such transactions as a way of reducing the tax impacts, thus distorting the objectives of the tax systems. Rui Guedes Henriques, Tiago Almeida Veloso and Ana Filipa Janine of Baker Tilly look at the VAT anti-abuse rules introduced in the 2012 budget to address these concerns.
  • Jens Wittendorf, of Deloitte Denmark, examines a recent dispute in the National Tax Tribunal (NTT) which highlights how unilateral anti-hybrid legislation can have the unintended consequence of eroding the domestic tax base.

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