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As resource-rich Middle Eastern governments suffer a decline in oil revenues, many governments are reforming transfer pricing (TP) regulations to limit capital flight. Deloitte’s Shiv Mahalingham, Alena Kovalova and Claire Boushell discuss the regional regulatory trends.

Gabriela Silva de Lemos explores the conflict between tax authorities and taxplayers as they strive to achieve a balance in concern of tax debt defaults.

Brazil's Federal Revenue Service provided important clarification regarding the concept of inputs for PIS and COFINS credits, but has still left much to discuss.

Brazil's complex federal and state structure has created a litigious framework for tax authorities, making tax reform in Brazil a continued political focus.

Public and political pressure has seen tax authorities play closer attention to transfer pricing. Deloitte’s Tony Anderson, Alex Evans, Mariusz Kazuch, Rafal Sadowski and Lian Tang He explore changes in Canada, China and Poland.

Cross-border cooperation in transfer pricing risk assessments and audits has presented cost saving opportunities, but increased reporting obligations for MNEs. Deloitte’s Manfred Naumann and David Varley explore the experience in Germany and the US.

Deloitte Touche Tohmatsu’s global transfer pricing practice, in partnership with International Tax Review, is pleased to present the 2019 edition of the Transfer Pricing Controversy Guide, a discussion and overview of the leading issues, challenges and opportunities around transfer pricing (TP) controversy.

Transfer pricing (TP) controversies have arisen in all countries. Deloitte’s Eric Lesprit, Sanjay Kumar and Joseph Tobin focus on recent TP controversy developments in three: France, India, and the US.

Are transfer pricing controversy cases on the rise because of the OECD’s BEPS initiative or local country legislation? Deloitte’s Stan Hales and John Henshall explore the dynamic globally.