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Transfer Pricing
A revised Chapter VII signals a move away from mechanical TP approaches, stressing transaction understanding, functional analysis and context-driven documentation requirements
June 18, 2026
features sponsored features special focus local insights
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HMRC’s growing focus on evidencing tax decisions is shifting attention from technical accuracy to governance, requiring businesses to demonstrate how positions were reached and documented -
In the second instalment of this two-part series, Jayne Stokes takes a practical approach to navigating the capital v revenue question for UK R&D claims for software development, and shares pointers for businesses
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Arindam Mitra and Robin Hart examine how aggregate TP rules clash with transaction-level customs rules, creating compliance risks and requiring granular, SKU-level pricing strategies
Sponsored Features
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Sponsored by DeloitteRonnie Dassen and Jan De Clercq of Deloitte Global outline how agentic AI can support indirect tax teams in managing compliance pressures, improving data quality, and freeing capacity for higher-value advisory work
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Sponsored by DeloitteSameer Nurmohamed, partner, Deloitte Legal Canada
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Sponsored by DeloitteGeorge Ankomah, partner, Tax & Regulatory Services, Deloitte Africa (Ghana)
Special Focus
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Sponsored by Deloitte USClaudia Lauten and Janis Sussick of Deloitte Germany assess how the accelerating digitalisation changes business models of multinational enterprises in the industrial products and construction industry.
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In collaboration with EY, ITR brings you practical insight into how tax departments across the Asia-Pacific region are approaching the challenges that have come to the forefront during 2020.
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Brazil's tax world is set to blossom in the 2020s. ITR has partnered with leading tax advisors to give you the key takeaways for the upcoming year and decade ahead.
Local Insights
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Sponsored by Lakshmikumaran & SridharanIndia has amended its GAAR to protect pre-April 2017 investments, but questions remain over application of the Supreme Court’s Tiger Global interpretation, say S Vasudevan, Giridhar Vasudevan, and Romil Hotwani of Lakshmikumaran & Sridharan
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Sponsored by GNV ConsultingFabian Abi Cakra and Aditya Nugroho of GNV Consulting outline how Indonesia’s new pillar two implementation rules establish registration, filing, reporting, and enforcement procedures for in-scope multinational groups under the global minimum tax regime
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Sponsored by GNV ConsultingFabian Abi Cakra and Erviyanti Adam of GNV Consulting explain how Indonesia’s revised MSME tax regime preserves the preferential 0.5% rate while tightening eligibility criteria and introducing new anti-avoidance measures aimed at business fragmentation
