Firm

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

Dutch taxpayers will be able to deduct more of their interest payments from their tax bills from 2025 – it could have an impact on the arm’s-length pricing of financial transactions

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

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

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

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

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

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

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

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

Åsa Edesten and Mazlum Yildiz of KPMG Sweden say there remains a lack of clear legal precedent on the impact of ‘control over risk’ in assessing contractual terms between related parties, despite a recent ruling

Join Tax Systems at 11am BST (12pm CEST) on October 17 to hear how transfer pricing documentation and processes can be managed more effectively in the face of enhanced scrutiny by tax authorities

The head of Skadden’s European tax practice said the recent Apple CJEU ruling could be the last of its kind as pillar two develops

While the rule could result in enhanced tax revenues, Egypt must consider its effect on foreign direct investment, say Rabie Morsy, Karim Adel, and Sandra Aziz of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt

The firm picked up awards for its work in multiple jurisdictions, while DLA Piper walked away with four individual honours

On a panel of advisers and tax authority representatives from a range of European jurisdictions, financial transactions were pinpointed as a key TP audit focus

Magdalena Marciniak and Agnieszka Krzyżaniak of MDDP consider whether two recent rulings indicate that Polish taxpayers can look forward to a more positive landscape for transfer pricing adjustments

A Swedish company’s CEO working part-time in Denmark led to a noteworthy PE decision; in other news, Latham & Watkins grew its London tax team

The lack of provision for bilateral advance pricing agreements is a notable omission from proposed reforms of Brazil’s transfer pricing rules

Federico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente report on a ruling by the Italian Tax Agency and explain an update to the deadline for the submission of income tax returns

Speaking exclusively at ITR’s Transfer Pricing Forum in Europe, the Commission’s Marc Clercx also addressed industry concerns over the arm’s-length principle

White & Case’s tax controversy head discusses how to stop a dispute before it starts and shares insights from a significant TP case with the IRS

Join ITR and insightsoftware at 2pm BST (3pm CEST) on September 24 to hear senior tax experts from KPMG Canada explain the evolving pillar two requirements and the transitional safe harbours – and consider what comes next

The court overturned a common and well-established position of the Italian tax authorities in a highly significant ruling, experts have told ITR

Both hires have extensive experience working for EY in the US

Jobst Wilmanns and Anodri Suchdeve of Deloitte Germany introduce this year’s ITR guide presenting transfer pricing insights across several industries, with analysis from Deloitte’s transfer pricing industry experts and factoring in global economic changes

Ralf Heussner of Deloitte Japan and Aaron Lee of Deloitte Singapore examine the latest transfer pricing trends impacting the banking sector in view of the implementation of the new Basel accord from 2025

Geoff Gill and Michael Manser of Deloitte Australia provide a guide to the upcoming public country-by-country reporting measures and how multinationals in the financial services sector should prepare for the first year of reporting

With ever-increasing challenges in the wholesale and retail industry, senior tax practitioners at Deloitte Germany consider the impact of amount B on the profit allocation of multinationals operating in the sector

Ishan Maini of Deloitte UK and Jay Das of Deloitte US say the need for technology, media, and telecommunications companies to analyse the risks associated with intercompany transactions has never been greater

Claudia Lauten, Janis Sussick, and Karen Smolka of Deloitte discuss how amount B could impact the tax and transfer pricing approaches of global multinational enterprises in the industrial products and construction sector

Richard Schmidtke, Heike Schenkelberg, and David Sauer of Deloitte Germany analyse the impact of specific characteristics of the life sciences and healthcare industry on the applicability of amount B

Mariani, global head of tax disputes at KPMG’s Netherlands arm, also outlined various dispute resolution strategies in an exclusive ITR interview 

Jobst Wilmanns and Anodri Suchdeve of Deloitte preview a guide to the latest transfer pricing trends, produced in collaboration between ITR and global transfer pricing industry experts from Deloitte

Amit Bhalla and Andrew Jackomos of HLB Thailand explain the Thai Revenue Code’s guidance in determining the nature of the relationship between two entities and whether transfer pricing disclosure forms are required

Legal battles involving the IRS, HMRC and ATO feature as companies have been ordered to pay vast sums

Federico Vincenti and Carola Valente of Crowe Valente/Valente Associati GEB Partners consider the ramifications of a ruling concerning the inclusion of loss-making companies in a transfer pricing benchmarking analysis as comparable entities

Work on the publication was co-funded by several European governments and the EU

Vortex Capital Partners will become a majority shareholder in TP Tuned, which specialises in TP documentation

Fernando Matesanz of Spanish VAT Services reports on a pronouncement by an EU member state on the impact that transfer pricing adjustments have on the VAT applied to transactions

Olga Trifonova began her new leadership role on July 1

The oral hygiene company is already fighting off a separate $20.4m TP demand from last year

ITR is delighted to reveal all the shortlisted nominees for the 2024 Americas Tax Awards

Consensus on the amount A multilateral convention will take more than six months to achieve, one expert believes

ITR is delighted to reveal all the shortlisted nominees for the 2024 Europe Middle East & Africa Tax Awards

ITR is delighted to reveal all the shortlisted nominees for the 2024 Asia-Pacific Tax Awards

There is a 'critical need' for a unified platform to address challenges in TP, the organisation’s president told ITR

Canada risks inflaming US trade relations in a presidential election year and increasing costs for consumers, according to local experts

Singapore faces controversies with many trade partners and needs to constantly keep tax guidelines up to date, a local tax expert told ITR

Karanjot Singh Khurana of Lakshmikumaran & Sridharan presents an Indian perspective on the transfer pricing implications of multinational corporations entering into global contracts that could affect group entities

PepsiCo succeeded by applying TP principles and employing ‘proper advisers’ in the appeal, one expert tells ITR

Ichwan Sukardi and T Qivi Hady Daholi of RSM Indonesia consider the Directorate General of Taxes’ increasing reliance on technology in transfer pricing evaluation, litigation developments in the area, resolution mechanisms, and mitigation strategies

But consenus achieved on 'vast majority' of issues and countries are 'still at the table', the OECD says

The insights of senior tax practitioners of Deloitte on recent practice in Argentina, Uruguay, Peru, and Colombia indicate an increasing amount of transfer pricing audit activity and a need for early preparation by taxpayers

Revised transfer pricing and permanent establishment compliance requirements are leading multinational corporations to consider the reorganisation of the maquiladora operating model through business restructuring, say Simón Somohano and Francisco Díaz of Deloitte S-LATAM

Mario Coyoy of Deloitte S-LATAM and Michelle Martinelli of Deloitte Panama note increasing transfer pricing scrutiny in several Central American jurisdictions as they step up their attempts to enhance transparency and ensure compliance

Vanesa Lanciotti of Deloitte Chile explains the country’s key transfer pricing-related measures as it seeks to increase its tax collection by 1.5% of GDP, with a new focus on tax compliance and financial governance

Carlos Ayub of Deloitte Brazil focuses on the challenges for organisations that trade commodities under the country’s new transfer pricing legislation and explains what methods and courses of action are available to in-scope taxpayers

While taxpayers fear unilateral measures in the event of no amount A agreement, it is likely the talks will continue until consensus is reached

The ruling for PwC’s client is a blow for the ATO and its ability to tax multinationals on complex cross-border transactions

As German clients attempt to comply with complex cross-border rules, local advisers argue that aggressive tax authorities are making life even harder

There will always be multinationals trying to minimise tax by pushing the boundaries of their cross-border arrangements, Rob Heferen claimed

Argentina, Brazil, Mexico and South Africa are among the countries the OECD believes could benefit from the simplified TP rules

However, making APAs harder to reach could ‘pose problems’ for UK businesses

Multinational enterprises must include transfer pricing and cost accounting experts in taking an integrated approach to supporting the arm’s-length nature of intragroup service charges, say Enrique Marchesi-Herce, Gilles Andreini, and Serena Picariello of Deloitte Luxembourg

Making cross-border purchases can save on VAT in the short term but TP issues may arise, an in-house tax expert suggested

More than 145 countries have now signed up to the deal since it was introduced in 2021

AI will speed up some of the most laborious TP processes without making human input redundant, argues Hank Moonen, CEO of TaxModel

Paolo Ludovici and Marlinda Gianfrate of Gatti Pavesi Bianchi Ludovici focus on how the simplified and streamlined approach set out in the OECD’s Pillar One – Amount B report enhances tax certainty

Authorities must ensure that Russian firms do not use transfer pricing schemes to increase profits made from oil sold in different markets, advocacy organisations have argued

Federico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente suggest what documentation can demonstrate the reasonableness of the costs of an intra-group transaction, and the benefits for a subsidiary

The OECD has revealed little about the progress of the talks on pillar one since February

The Australian Taxation Office scored a victory over the company last year in a case that will be closely watched by other multinationals

A multinational enterprise bearing the cost of an employee stock option plan granted to an Indian subsidiary creates several complexities, as explained by S Vasudevan, Harshit Khurana, and Sonali Bansal of Lakshmikumaran & Sridharan

Adrian Rus and Georgiana Bizdrigheanu of EY Romania explain the options for the country’s taxpayers in tackling double taxation and suggest how predictability and efficiency can be improved

The US is capitalising on a fertile deals market to take centre stage in tax talent recruitment, according to insights from ITR+’s Talent Tracker

With transfer pricing principles becoming increasingly important as start-ups expand, Nouran Ibrahim and Maureen Guirguis of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt explain the salient points and how to meet the challenges

Balazs Majoros of Deloitte Luxembourg provides an update on the transfer pricing landscape in the grand duchy against a backdrop of opposition to a draft bill and winds of change from the EU

Proposed regulations on corporate excise tax pose challenges on different fronts, experts tell ITR

The finalists for the 13th annual awards have been revealed

Mazars needs to do all it can to capitalise on TP as a growth area, ex-Deloitte TP director Jeremy Brown has told ITR

Paolo Ludovici and Luca Tortorella of Gatti Pavesi Bianchi Ludovici highlight two recent Italian tax court decisions regarding admissibility to mutual agreement procedures where the double taxation derives from self-adjustments rather than formal assessments

Multinational enterprises that conduct intra-group transactions in EU jurisdictions should be closely monitoring a proposed transfer pricing directive, say João Velez de Lima and André Vilaça Ferreira of Vieira de Almeida

Luis Coronado suggests companies should embrace technology to assist with TP data reporting, as the ‘big four’ firm unveils a TP survey of over 1,000 professionals

The proposed matrix will help revenue officers track intra-company transactions from multinationals

Federico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente analyse a significant addition to Italy’s case law on the application of transfer pricing regulations to interest-free loans between related parties

The new, fully integrated office will also offer M&A, dispute resolution, IP and corporate tax services

The new tech partnership will assist clients worldwide with pillar two; in other news, UK accountancy firm MHA completes a regional merger

Ralf Heussner, Anodri Suchdeve, and Fangying Xu of Deloitte examine the transfer pricing challenges arising from an increasing number of intra-bank funding arrangements as stricter capital requirements trigger the attention of regulators and tax authorities

The retail pharmacy chain owner ‘intends to vigorously defend’ its TP position

Jeremy Brown arrives at the firm after a near 16-year career with Deloitte

Their prediction comes after the IRS announced it would send compliance letters to large foreign companies emphasising their US tax obligations

Ichwan Sukardi and T Qivi Hady Daholi of RSM Indonesia explain the clarifications provided by the latest Indonesian transfer pricing regulation, but point out that uncertainty remains around several issues

Mark Martin and Thomas Bettge of KPMG in the US discuss the first published statistics on the International Compliance Assurance Programme and their implications for businesses looking to obtain tax certainty

The appeal related to deductions claimed by the Singaporean telecoms company, which was advised by PwC, on a A$5.2 billion acquisition from 2002

Monika Bieri and Daniel Schönenberger of Tax Partner AG analyse a recent Federal Administrative Court case and its implications for current transfer pricing practice in Switzerland

With South Korea expected to take a more aggressive approach to auditing, tax partners from Yulchon analyse four transfer pricing-related rulings that provide guidance for multinationals

Mark Martin and Thomas Bettge of KPMG in the US discuss the recent amount B consensus document and the associated compliance challenges

Oscar Campero, Yoshio Uehara, and José Luis Iglesias of Chevez Ruiz Zamarripa provide a guide to the most commonly scrutinised concepts and the documentation required by the Mexican tax authority in transfer pricing audits

Rob Clary observed that clients ‘have an expectation you can operate globally’ and that Baker McKenzie is well positioned to meet the demand

Federico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente report on the publication of guidelines concerning the compensation of asset managers that provide services to entities within the same group

Experts from TP tech provider Aibidia also warned ITR that companies ignoring pillar two is a ‘huge issue’ and a ‘red flag’

As the Nigerian government aims to boost its tax revenue, Taofeek ’Bola Shittu of Ikeyi Shittu & Co. explains how to minimise the risk of additional tax liability resulting from non-compliance with transfer pricing regulations

Charles Setia Oetomo, Felic Setiawan, and Gomgom Johannsen Kevan of GNV Consulting provide a guide to Indonesia’s new transfer pricing regulation, what to expect, and how taxpayers may prepare for its application

Tami Putri Pungkasan and Yurike Yuki of DDTC Consulting say an Indonesian transfer pricing update recognises the prevention of double taxation as a purpose and not merely as a means to prevent tax avoidance

Amount B is meant to increase simplicity and reduce uncertainty, but US TP specialists claim it may lead to controversy

Ingrid Faxing and Henri Ahtiainen of Skeppsbron Skatt analyse a proposal to incorporate the OECD Transfer Pricing Guidelines into EU law and question whether it will become a reality after several objections

Barbara Voskamp is bullish on hiring local talent to boost DLA Piper’s Singapore practice, and argues that ‘big four’ accountants suffer from a stifled creativity

Ralf Heussner, Alison Lobb, and Yvonne Weigelt of Deloitte conclude their summary of an interview with Manuel de los Santos, head of the transfer pricing unit at the OECD’s Centre for Tax Policy and Administration

But the US tax agency’s advice is consistent with OECD guidance and shouldn’t surprise anyone, other experts tell ITR

Join ITR and insightsoftware at 2pm GMT (3pm CET) on March 20 2024 to hear about the increased reporting complexities introduced by pillar two and how to navigate them through efficient management of data

The report is aimed at helping 'low-capacity countries', the OECD has claimed

Yasmine Hammad, Haidy Elaasser, and Mahmoud Ashraf of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt conclude a two-part series on transfer pricing audits in Egypt by anticipating the changes under the newly established automated process

In the first article of a two-part series on transfer pricing audits in Egypt, Yasmine Hammad, Haidy Elaasser, and Mahmoud Ashraf of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt explain the current process

However, ICAP may not provide the legal certainty of an APA and tax authorities will have limited capacity, experts argue

Ralf Heussner, Alison Lobb, and Yvonne Weigelt of Deloitte reveal further insights from an interview with Manuel de los Santos, head of the transfer pricing unit at the OECD’s Centre for Tax Policy and Administration

Fabian Abi Cakra and Danang Syailendra of GNV Consulting explain how several Indonesian transfer pricing regulations have been combined into new legislation, and summarise changes to employee income tax under a withholding tax regulation

Interview with Chris Atkinson, partner, tax and legal, Deloitte Australia

Interview with Eric Lesprit, partner, transfer pricing, Deloitte Société d’Avocats, France

Federico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente explain the revised timeframes and requirements for Italian taxpayers submitting transfer pricing documentation and aiming to benefit from the penalty protection regime

Jun Au and Jock McCormack of DLA Piper Australia provide an update on several significant pieces of draft legislation concerning the petroleum resource rent tax and related matters

The firm has continued its expansion efforts by raiding from the ‘big four’ once more

A three-part weekly series begins with Ralf Heussner, Alison Lobb, and Yvonne Weigelt of Deloitte sharing insights from an interview with Manuel de los Santos, head of the transfer pricing unit at the OECD’s Centre for Tax Policy and Administration

Lewis Lu and Xiaoyue Wang of KPMG China consider issues with conducting year-end transfer pricing adjustments in China

Tax advisers can’t afford to ignore cryptocurrency if they want deeper client relationships, argues Pretino Albury of Kreston Global

Ralf Heussner, Alison Lobb, and Yvonne Weigelt from Deloitte’s global transfer pricing network preview a series based on an interview with the head of the transfer pricing unit at the OECD’s Centre for Tax Policy and Administration

The ‘big four’ firm hopes the new technology will make client service more efficient, while Pinsent Masons has appointed a new tax head in Dublin

There is definitely a role for ICAP in TP compliance for multinational enterprises, a TP leader told ITR

Yong Chan Lee and Eun Jin Choi of Deloitte Korea provide an update on the application of the OECD’s two-pillar solution and explain how Korean businesses can prepare for amount B’s introduction

Nouran Ibrahim and Haidy Elaasser of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt explain what supporting evidence should be kept in readiness for potential queries raised by the Egyptian Tax Authority at times of audit

Sanjay Kumar and Suchint Majmudar of Deloitte India provide a guide to the BEPS package and explain why streamlining the calculation of amounts A and B is integral to its successful implementation

The letters don’t reflect final determinations that the taxpayer has underpaid US taxes, tax experts argue

RSM’s European leader tells ITR of surging pillar two client demands and capitalising on disillusioned talent from the ‘big four’

Compliance alerts have been sent to more than 180 subsidiaries of large foreign corporations, emphasising their US tax obligations

HM Revenue and Customs has received warnings from consultation respondents including the ‘big four’

Dinko Dinev and Ismail Candan of Deloitte Luxembourg explain how tailored transfer pricing policies can underpin success as the increasing complexity of debt investment instruments and heightened regulatory oversight demand enhanced tax compliance measures

The international firm’s new addition will also provide corporate, indirect tax compliance and dispute resolution services

Dispute resolution, TP compliance costs and the proposal’s consistency with OECD principles have all come under the microscope

Mark Martin and Thomas Bettge of KPMG in the US discuss the issue of implicit support and a recent IRS advice memorandum addressing transfer pricing for intercompany debt

The Dutch Ministry of Finance no longer considers the UAE a low-tax jurisdiction, while 2024 marks the start of new roles for tax partners

Transfer pricing, alleged tax fraud and disputes over back taxes all feature in this year’s ITR list of tax cases to watch

The US Internal Revenue Service could consider a company’s membership in a corporate group when deciding on an interest rate for an intragroup loan extended to the firm

To avoid ambiguities, interpretation difficulties and possible conflicts, the directive should stay as close as possible to OECD guidelines, the tax group has recommended

Michael Puls will start at the ‘big four’ firm on January 2 2024, servicing clients both domestically and internationally

Multinational companies face numerous year-end tasks but should not forget to file the treaty notifications that are required in certain US tax treaties, say senior tax practitioners from KPMG in the US

Multinationals importing goods in the APAC region face varying compliance requirements across the jurisdictions. Shubhendu Misra and Michiel Friedhoff of EY explain several approaches to managing and avoiding disputes with the customs authorities

EU member states are exclusively competent to define their national tax rules, the Court of Justice of the EU has ruled in a case concerning Amazon

Amount B promises to streamline a fundamental TP issue but unresolved issues remain, accountancy institutes have argued

Carola Valente of Crowe Valente/Valente Associati GEB Partners explains the application of the OECD Transfer Pricing Guidelines to financial transactions as multinationals increasingly centralise their treasury functions

Politicians may feel entitled to an explanation of Microsoft’s TP strategy following the IRS’s probe, but whether they receive it is another question, a senior tax expert warns

The European Commission hasn’t sufficiently justified certain choices and there should be a stronger TP role for the European Parliament, a politician has claimed

The metal multinational’s victory, in a case worth $12 million, continues the trend of companies coming out on top against India’s revenue department

Mark Martin and Thomas Bettge of KPMG in the US analyse the 2022 mutual agreement procedure statistics for the US and discuss their significance for businesses

Nouran Ibrahim and Hana Khalil of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt discuss the rationale and basics of implementing mechanisms for the correct administration of central/intra-group service charges

The order comes amid controversy over another of David Collard’s companies’ tax and TP affairs

NASSCOM, which represents over 3,000 Indian companies, has argued for the removal of the segmentation rule

ITR invites tax firms, in-house teams, and tax professionals to make nominations for the 2024 ITR Tax Awards in the Americas, EMEA, and Asia-Pacific

More people working on transfer pricing disputes and treating cases seriously may contribute to the country’s speedy process, Sandra Knaepen suggests to ITR

The CJEU advocate general’s opinion represents a shift in Apple’s EU state aid litigation but experts argue the saga isn’t over

The Netherlands took the shortest amount of time to close transfer pricing cases, beating Switzerland and Denmark to the award

The tribunal rejected the revenue department's appeal in a transfer pricing case related to the 2004-05 assessment year

Ana Helena Farinha and Tiago Martins de Oliveira of Cuatrecasas say that the intragroup financing of Portuguese companies could be affected by a rule that is out of kilter with several other EU jurisdictions

The European Commission experts responsible for TP legislation say the proposed rules have been well-received by businesses

The ruling undermines Coca-Cola’s challenge in a dispute which is the final part of a $3.4 billion TP case

Specific schedules for bauxite and lithium aim to bring a transfer pricing value uplift to developing countries, OECD expert Andrew Viola tells ITR

Carola Valente of Crowe Valente/Valente Associati GEB Partners explains why ESG goals and requirements are intertwined with transfer pricing, and how multinationals can mitigate the associated risks throughout value chains

A regulatory board is understood to have cleared the acquisition of PwC Australia's former government consulting wing

The proposal will add to political disagreements over the international tax system, policy guru Adam Michel has argued

The oral hygiene company intends to address the order through alternative dispute resolution

His selection comes after US head Tim Ryan’s exit from the firm despite being a top contender for the role

Panellists clashed on pillar one in particular, with a tax reformist saying the project is like ‘a pillar of ice that has been left in the sun too long’

A new discussion has opened at the UN on how the arm’s-length principle works in the context of two important industries

New guidance on TP regulation is welcome but flaws remain, according to local tax experts

Taxpayers have more time to analyse the impact of the new rules but disputes are likely, according to counsel

Federico Vincenti and Alessandro Valente of Crowe Valente/Valente Associati GEB Partners report on a decision regarding the taxation of intercompany transactions based on the activities of a branch and its parent company

The company doesn’t agree with historical adjustments amid a dispute that mainly concerns transfer pricing.

Low- and middle-income countries are expected to gain the most as a share of corporate income tax revenues, the OECD has claimed.

Karolina Ibranyi-Matkovits and Michal Stepien of Deloitte Luxembourg summarise crucial research on how debt capacity is managed across Europe, and outline how taxpayers are building sustainable positions.

Conversations with tax officials could run more efficiently if they had more expertise, a senior TP figure suggested at an ITR conference in London.

Join ITR and Deloitte Luxembourg at 4pm CET (3pm GMT, 10am EST) on November 9 2023 to hear about strategies to effectively manage transfer pricing controversy, and the latest market developments in the area of financial transactions transfer pricing.

A senior tax figure took aim at the OECD’s recent record on creating simplicity through its policy proposals, at an ITR conference in London.

PwC publishes detailed accounts of its behaviour in the tax scandal in Australia, while another tax trial looms for pop star Shakira.

Senior figures from Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt comment on the explanatory guide issued by the Egyptian Tax Authority regarding the application of TP rules in the country.

The winners of the ITR Europe, Middle East, and Africa Tax Awards 2023 have been announced!

The winners of the ITR Asia-Pacific Tax Awards 2023 have been announced!

Mauro Faggion appeared cautiously optimistic as the European Commission waits to see whether all 27 member states will accept its proposal.

The global minimum rate also won’t entirely stop a race to the bottom, according to a tax director speaking at an ITR conference in London.

Vrajesh 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.

Froukje 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.

Aaron 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.

Christine 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.

Kirsti 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.