Editor’s picks: ITR’s top stories of 2025
ITR’s most prolific stories of the year charted public pillar two spats, the continued fallout from the PwC tax leaks scandal, and a headline tax fraud trial
Italy: Guide to cross-border transactions, APAs, and exchange of information
Federico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente analyse Italy’s cross-border tax and transfer pricing rules under DAC3 and DAC8
Management PEs in Portugal: finding a needle in a haystack?
Tiago Marreiros Moreira and Francisca de Landerset of VdA explain the challenges of attributing profits to a management permanent establishment in Portugal, highlighting OECD guidance, board member activities, and documentation requirements for compliance
Exclusive: 92% of executives expect more disputes from pillar two
An EY survey of almost 2,000 tax leaders also found that only 49% of respondents feel ‘highly prepared’ to manage an anticipated surge of disputes
Avoiding a ‘delayed time bomb’: how master file documentation impacts Polish WHT
Magdalena Marciniak and Gniewomir Parzyjagła of MDDP explain how Poland’s master file requirements increasingly influence withholding tax outcomes and why aligning group documentation with local rules is essential to avoid significant audit risks
Hungary seeks feedback on revised TP documentation requirements
The proposal seeks to regulate compulsory TP documentation in line with the OECD Transfer Pricing Guidelines and simplify filing requirements
Podcast – TP audits: how to avoid the red flags that trigger scrutiny
Tax authorities in Europe are stepping up their transfer pricing focus. A podcast held by ITR in collaboration with CMS explores what multinational enterprises can do to mitigate risk
Transfer pricing and loss situations
Defending loss situations in TP is not about denying the existence of losses but about showing, through proactive measures, that the losses reflect genuine commercial realities