Deloitte’s 2021 survey on the global TP controversy landscape Vrajesh Dutia and Ananthanarayanan R of Deloitte analyse the results of a TP controversy survey, involving TP practitioners across the globe, which seeks to gain a better understanding of the... By Vrajesh Dutia & Ananthanarayanan R July 20 2021
The cause-and-effect relationship between COVID-19 and tax controversies: Risk manageme... Manisha Gupta, Iva Georgijew and Bhupendra Kothari of Deloitte discuss the transfer pricing risks that may arise due to business disruptions caused by COVID-19 with recommendations on how to manage... By Iva Georgijew & Bhupendra Kothari & Manisha Gupta July 20 2021
Country-by-country reporting and COVID-19: CbC data is becoming a big deal in TP contro... Juan Ignacio de Molina and Christine Ramsay of Deloitte consider the increased reliance of tax authorities on CbCR data and how the data reported in the CbCR during the COVID-19... By Juan Ignacio de Molina & Christine Ramsay July 20 2021
TP controversy: The dynamic landscape of intangibles arrangements Shaun Austin, Richard Schmidtke and Aparna Rao of Deloitte discuss the challenging transfer pricing concepts of intangibles arrangements and important regulatory changes from Australia and Germany. By Richard Schmidtke & Shaun Austin & Aparna Rao July 20 2021
How will the G20/OECD’s pillar one and pillar two project affect disputes? Alison Lobb and Howard Osawa of Deloitte explore potential areas of controversy arising from the G20/OECD’s pillar one and pillar two project and considerations to manage disputes and potential double... By Alison Lobb & Howard Osawa July 20 2021
TP developments are rapidly creating the new normal in global TP controversy Kerwin Chung and Carlo Llanes Navarro of Deloitte provide an insight into ITR’s transfer pricing controversy guide, produced in collaboration with global transfer pricing experts from Deloitte. By Kerwin Chung & Carlo Llanes Navarro July 20 2021
Multilateral dispute resolution initiatives: Time for a global reset? Eric Lesprit and John Breen of Deloitte look to the future of transfer pricing dispute resolution, including the proposals in the OECD’s pillar one digital tax blueprint, multilateral negotiations and... By Eric Lesprit & John Breen July 20 2021
MAP developments in the desk-bound age Edward Morris and Jamie Hawes of Deloitte discuss how the resolution of controversy has changed with the introduction of a more efficient system to handle MAPs and APAs. By Edward Morris & Jamie Hawes July 20 2021
A closer look at debt transactions in practice Ariel Krinshpun, James Mahon and Mo Malhotra of Deloitte explain why taxpayers may wish to review intra-group financing arrangements, and significant financing transactions in particular, for controversy risk. By Mo Malhotra & Ariel Krinshpun & James Mahon July 20 2021
Deloitte’s TP controversy guide: The changing landscape of TP controversy - 2021 and be... Kerwin Chung and Howard Osawa of Deloitte preview ITR’s upcoming transfer pricing controversy guide, produced in collaboration with global transfer pricing experts from Deloitte. By Kerwin Chung & Howard Osawa July 06 2021
