Transfer pricing controversy trends – Deloitte’s 2024 global survey
Shaun Austin, Darcy Alamuddin, and Ryan McMahon of Deloitte analyse the feedback from the 2024 Deloitte transfer pricing controversy survey, highlighting key trends in the transfer pricing controversy space
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Sponsored by DeloitteMariusz Każuch, Inka Traeger, and Conrad Marburg of Deloitte consider tax authorities' recharacterisation of intercompany transactions through drawing on recent practice in Poland and Germany, and suggest proactive measures global businesses can take -
Sponsored by DeloitteVrajesh Dutia and Michael Nixon of Deloitte explain the nuances of amount B as jurisdictions consider its adoption, and outline the uncertainties and challenges involved
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Sponsored by DeloitteAaron Wang, Carlo L Navarro, and Rebecca Cook of Deloitte explain several Asia-Pacific jurisdictions’ differing approaches towards the construction of an arm’s-length range amid the shifting contours of the region’s transfer pricing landscape
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Sponsored by DeloitteCarlos Serrano Palacio, Richie Lombard, and Bernardo Misle of Deloitte analyse recent measures to resolve tax uncertainty in a climate of increasing transfer pricing audits and controversy, and consider what further steps should be taken
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Sponsored by DeloitteWith the pricing of intangibles laced with difficulty, Ishan Maini, Eric Linge, and Richard Schmidtke of Deloitte draw on two cases in Germany and Israel revolving around differing interpretations concerning the delineation of transactions
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Sponsored by DeloitteThe complex distinction between legal ownership and economic ownership of intangible assets means multinationals must take proactive measures to avoid transfer pricing controversy, say Christine Ramsay, Jordi Morera, and Marguerite Mei of Deloitte
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Sponsored by DeloitteMultinationals attempting to avoid and mitigate penalties potentially arising from transfer pricing controversy could take a tip from standard exam advice. Eddie Morris and Aydin Hayri of Deloitte explain the importance of recording actions
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Sponsored by DeloitteNicola Lostumbo and Jie Pan of Deloitte provide insights into high-value intercompany service charges, their role in creating value, and the most common tax authority challenges, before concluding with some considerations in mitigating risks
Deloitte TP Controversy Guide Archive
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Sponsored by DeloitteAaron Wang of Deloitte China and Iva Georgijew of Deloitte Poland set out the key questions when limited risk and low-risk distributors incur losses, and consider the challenges presented in several common scenarios.
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Sponsored by DeloitteVrajesh Dutia of Deloitte India and Jennifer Breeze of Deloitte UK assess the complex arm’s-length decisions that global businesses had to make during the COVID-19 pandemic, and the various responses from international tax authorities.
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Sponsored by DeloitteEdward Morris of Deloitte UK and Sobhan Kar of Deloitte India question whether the adage that mutual agreement procedures work, but too slowly, is still correct.
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Sponsored by DeloitteFroukje Frerichs, Stefano Lavore, and Nicola Lostumbo of Deloitte provide a guide to the most common tax authority challenges in the business restructuring context and present a three-pronged approach to mitigating this risk.
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Sponsored by DeloitteGeoff Gill of Deloitte Australia and Andrew Skipsey of Deloitte UK analyse the use of profit split transfer pricing methods in the rapidly evolving banking and commodity trading businesses.
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Sponsored by DeloitteSimón Somohano and Francisco Díaz of Deloitte S-LATAM explain the changes for maquiladoras after the repeal of advance pricing agreements as a compliance option and the implications for Mexico’s competitiveness as a manufacturing location.
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Sponsored by DeloitteAriel Krinshpun and James Mahon, III of Deloitte US and George Galumov of Deloitte Switzerland analyse two areas of intercompany financing arrangements as transactions come under increasing scrutiny from tax authorities.
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Sponsored by DeloitteKirsti Longley of Deloitte Tax LLP and Carlos Serrano Palacio of Deloitte Spain explain the benefits of advance pricing agreements in managing transfer pricing exposure, and the pros and cons of unilateral and bilateral advance pricing agreements.
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Sponsored by DeloitteChristine Ramsay and Samer Wani of Deloitte Canada and Subhabrata Dasgupta of Deloitte Malaysia highlight significant legislative developments in several jurisdictions as the world strives to keep pace with the OECD's Transfer Pricing Guidelines.
