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TP controversy: Prevention is better than cure

In collaboration with tax experts from Deloitte member firms around the world, ITR’s Transfer Pricing Controversy guide provides strategies to help avoid and resolve disputes as tax authorities resume pre-pandemic levels of activity.

Paul Riley, September 27 2022

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TP documentation – building a strong first line of defence against disputes

Increased transfer pricing documentation requirements are not reducing the number of disputes. Jennifer Breeze, Chris Ferguson, and Simón Somohano of Deloitte offer regional perspectives on the issue and explain what businesses may be able to do to prevent escalation.

Jen Breeze, September 27 2022

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Differences in interpretation in applying BEPS changes

Rather than simplifying and standardising international tax, the OECD BEPS recommendations have led to a complex landscape. Vrajesh Dutia and Eric Lesprit of Deloitte analyse the application of the guidance across several high-profile jurisdictions.

Vrajesh Dutia, September 27 2022

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APA implementation in India and China under the spotlight

Sobhan Kar of Deloitte India and Aaron Wang and Michael Sun of Deloitte China evaluate the use of advance pricing agreements in their jurisdictions, and consider how both countries’ programmes are likely to evolve.

Sobhan Kar, September 27 2022

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Common themes in TP controversy across industries

Eddie Morris and Markus Kircher of Deloitte consider the common causes of transfer pricing (TP) disputes in the automotive and media sectors.

Eddie Morris, September 27 2022

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TP considerations arising from remote working, digitalisation, and business restructuring

Shaun Austin, Karishma Phatarphekar, and Jack Smith of Deloitte consider three factors that are driving changes to business models and set out best practice for transfer pricing professionals in handling the tax implications.

Shaun Austin, September 27 2022

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Proactive engagement with tax authorities and wider ESG considerations

Increased transparency requirements have pushed the management of tax risk higher up companies’ agendas. Juan Ignacio de Molina, Yoshihiro Adachi, and Carlos Serrano of Deloitte explain how corporate governance and cooperative programmes can help.

Juan Ignacio de Molina, September 27 2022

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Tax authority requests for information – managing TP evidence across your enterprise

Sophie Brown and Sarah Blakelock of Deloitte highlight the lessons to be learnt from transfer pricing disputes and case law as tax authorities increasingly pursue data interrogation, source data, and access to emails.

Sophie Brown, September 27 2022

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Achieving TP closure: Treaty MAP arbitration

Eddie Morris of Deloitte considers the limited evidence available on the use of the arbitration clause of mutual agreement procedure articles to resolve transfer pricing disputes, and pinpoints areas for improvement.

Eddie Morris, September 27 2022

Contractor concept. Yellow hardhat, libella and plans on the gray tiles.

Pillar one’s safe harbour falls short of industry expectations

Sources say they are not satisfied with pillar one protections in the marketing and distribution safe harbour, even though it was designed to give businesses greater tax certainty.

Danish Mehboob, September 26 2022

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