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Perspectives

Transfer pricing articles

Read the latest articles on topics related to transfer pricing, first published in International Tax Review.

Deloitte publishes articles regularly on topics related to transfer pricing. The following is a collection of articles written by Deloitte transfer pricing specialists, and is reproduced with permission of International Tax Review, where they were first published.

gx-tax-2019.JPG (644×841) Transfer pricing in 2019
Deloitte’s global transfer pricing practice, in partnership with International Tax Review present the 2019 edition of the Transfer Pricing Controversy Guide, a discussion and overview of the leading issues, challenges and opportunities around transfer pricing (TP) controversy.

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gx-tax-apas.JPG (455×649) APAs: A leading practice to resolve and avoid TP disputes
Multinationals are increasingly resorting to advance pricing agreements (APAs) to manage tax disputes globally. With costs and processing times falling, Deloitte’s Kerwin Chung, Aldo Castoldi, and Luke Tanner discuss their implications in the US, Japan and Europe.

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gx-tax-audits.JPG (452×646) What the tax authorities are up to: Key audit trends globally
Public and political pressure has seen tax authorities play closer attention to transfer pricing. Deloitte’s Tony Anderson, Alex Evans, Mariusz Kazuch, Rafal Sadowski and Lian Tang He explore changes in Canada, China and Poland.

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gx-tax-beps.JPG (452×645) Chicken or the egg: TP, BEPS, and local- country legislation
Are transfer pricing controversy cases on the rise because of the OECD’s BEPS initiative or local country legislation? Deloitte’s Stan Hales and John Henshall explore the dynamic globally.

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gx-tax-controversy.JPG (456×644) A national perspective: TP controversy in France, India, and the US
Transfer pricing (TP) controversies have arisen in all countries. Deloitte’s Eric Lesprit, Sanjay Kumar and Joseph Tobin focus on recent TP controversy developments in three: France, India, and the US.

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gx-tax-controversy-strategy.JPG (646×914) Transfer pricing controversy, strategy and future direction
Transfer pricing controversy has become more frequent and complex following the OECD’s BEPS initiative. Deloitte’s Shaun Austin, Darcy Alamuddin and Jamie Bedford explore how companies can strategically respond and reduce its associated risks.

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From best endeavours to binding arbitration: Eliminating double taxation
Mutual agreement procedures (MAPs) are becoming increasingly popular in the settlement of TP controversy. As double taxation fears abound for multinationals, Deloitte’s Edward Morris discusses the importance of a well-functioning MAP process.

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An industry perspective: Financial services, life sciences and automotives
Post-BEPS, TP controversy has affected all industries. Deloitte’s Ralf Heussner, Aydin Hayri and Juan Ignacio de Molina explore the impact on the financial services, life sciences and automotive industries.

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gax-tax-joint-audits.JPG (590×836) Joint audits, ICAP, and the role of risk assessment
Cross-border cooperation in transfer pricing risk assessments and audits has presented cost saving opportunities, but increased reporting obligations for MNEs. Deloitte’s Manfred Naumann and David Varley explore the experience in Germany and the US.

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