Expert Analysis

Dear readers,

Shanto Ghosh, John Wells, and Todd Wolosoff discuss the recent stages in the OECD’s project into the transfer pricing aspects of intangibles and comment on the inconsistencies in the draft and what these could mean for taxpayers.

The valuation of intellectual property (IP) for transfer pricing purposes has recently received a lot of attention from the US government. Philippe Penelle and Lawrence Shanda take taxpayers through the specifics of IP valuation, payment forms and discount rates, in light of the IRS’s new focus on migrated IP.

Join Grant Thornton and insightsoftware on April 23 for a free ITR webinar exploring how flexible tax software aligns with your existing processes, enabling smoother adoption, integration, and phased implementation across complex organisations

Join ITR for a free webinar on February 4 as senior tax practitioners from BDO India analyse a highly significant ruling by the Indian Supreme Court

Interview with Candy Ye Tang, tax and business advisory leader, Deloitte China

Antonio Ruiz and Alejandra Arguedas of EY Central America, Panama and Dominican Republic explain how tax, geopolitical factors, and trade agreements shape foreign investment in Central America, offering guidance for companies navigating the region

David 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

Eddie 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

Maria Gouveia of Morais Leitão, Galvão Teles, Soares da Silva & Associados examines the most widespread misconceptions surrounding the regime, clarifying its tax deferral mechanism, effective rates, eligibility criteria, and scope

Rafael Calvo Salinero and Fernando Brioso de la Rica of Garrigues examine the implications of a Spanish Supreme Court ruling on treaty relief when the Interest and Royalties Directive exemption is denied

Federico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe Valente examine the challenges and methodologies involved in determining arm’s-length prices for transactions involving intangible assets, addressing how to ensure compliance and mitigate tax risks