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Sponsored by DeloitteIncreased 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. -
Sponsored by DeloitteRather 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.
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Sponsored by DeloitteSobhan 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.
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Sponsored by DeloitteEddie Morris and Markus Kircher of Deloitte consider the common causes of transfer pricing (TP) disputes in the automotive and media sectors.
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Sponsored by DeloitteShaun 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.
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Sponsored by DeloitteIncreased 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.
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Sponsored by DeloitteSophie 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.
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Sponsored by DeloitteEddie 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.
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Sponsored by Ritch MuellerSantiago Llano and Eric Palacios of Ritch Mueller explain why non-Mexican residents should analyse whether Mexican source income exists when transferring participation in a non-Mexican resident entity that owns directly or indirectly immovable property in Mexico.
