Transfer pricing: How to work faster, smarter and more compliantly
Specialist technology can save companies time, money and compliance stress by revolutionising a multitude of TP processes, says Russell Gammon of Tax Systems
Romanian tax authorities ramp up their analysis of intercompany financing
Monica Chiriac and Adrian Rus of EY Romania say multinational enterprises with Romanian affiliates should take proactive measures to ensure they are well prepared for increasingly intense scrutiny of intercompany financial transactions
‘An uncertain environment’: US experts criticise IRS TP memorandum
The memorandum raises concerns and taxpayer challenges should be expected, four experts tell ITR
UN committee mulls TP paper on pharma industry
The committee is deciding whether to add the appendix to existing guidance for tax administrations when scrutinising MNE activities
Navigating DEMPE in TP: IP ownership and economic return allocation
Companies that master the DEMPE analysis of their intangibles stand to benefit from a greater economic return, writes Mohamed Haj Taieb, partner at CMS France
Guide to Italy’s 90-day extension possibility for TP documentation
Federico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente explain how taxpayers can gain extra time to complete transfer pricing documentation and thus take advantage of Italy’s ‘penalty protection regime’
Africa-based companies ‘unlikely’ to be hit by pillar one
Meanwhile, African revenue authorities expect their next taxable income to come from TP and from a larger share of the global tax bill, one expert tells ITR
‘Amount B doesn’t take disputes off the table’: TP Forum
Amount B was top of the agenda at ITR’s US Transfer Pricing Forum 2024, while there were also heated discussions on the US’s potential adoption of pillar two
HMRC guidelines on common TP risks hailed as a ‘game changer’
HMRC is 'showing us what good looks like', one expert has claimed
TP dispute trends in Europe: how to manage the rising tide
Senior tax practitioners from five member firms of the Taxand network provide insights into enhanced tax audit scrutiny of transfer pricing in their jurisdictions and suggest several means of recourse for taxpayers