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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 ATOZRomain Tiffon and Marie Bentley of ATOZ analyse how automation, data analytics, and generative AI are reshaping tax operations, enabling greater strategic insight while raising important challenges around data, governance, and implementation
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Sponsored by YulchonSeveral South Korean transfer pricing cases have established clearer judicial standards emphasising robust comparability analysis and stronger functional and economic evidence. Yulchon tax partners provide practical insights for navigating the heightened requirements
Local Insights
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Sponsored by Steadfast Business ConsultingIn the first article of a three-part series, Mithilesh Reddy of Steadfast Business Consulting decodes a memorandum issued by the Dutch tax authorities that addresses implicit support and recharacterisation, and explains the implications for multinationals
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Sponsored by Steadfast Business ConsultingMithilesh Reddy of Steadfast Business Consulting concludes the series by analysing the Dutch Tobacco BV ruling and approaches to transfer pricing guarantee fees in the Netherlands, India, and the UAE
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Sponsored by Steadfast Business ConsultingMithilesh Reddy of Steadfast Business Consulting continues his analysis of the May 2025 memorandum issued by the Dutch Coordination Group on Transfer Pricing, focusing on the conditions that guarantee fees must meet
