Deloitte TP Controversy Guide 2024

Mariusz 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

Vrajesh Dutia and Michael Nixon of Deloitte explain the nuances of amount B as jurisdictions consider its adoption, and outline the uncertainties and challenges involved

Aaron 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

Carlos 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

With 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

The 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

Multinationals 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

Nicola 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