ITR (International Tax Review)

As remote work and flexible arrangements become the norm, the location of key decision-makers is increasingly becoming a critical tax risk for multinational enterprises. Monika Bieri and Daniel Schönenberger of Tax Partner use a Swiss perspective to examine how workforce mobility is actively reshaping transfer pricing models. #GlobalMobility #TransferPricing #TaxPartner #RemoteWork #SwissTax #ITR

Geopolitical conflict and economic volatility are actively reshaping transfer pricing risk and enforcement. Ichwan Sukardi and T Qivi Hady Daholi of RSM Indonesia examine how these shifts are impacting the landscape, with a specific focus on Southeast Asia and Indonesia. Read their insights on moving from basic compliance to true resilience. #TransferPricing #TaxCompliance #RSMIndonesia #APAC #InternationalTax #ITR

Several recent Swedish court cases are raising critical questions about how control over risk is applied during group restructurings involving intellectual property. Patrik Sedlar and William Berntö of Svalner Atlas Advisors explore whether the Swedish Tax Agency’s approach to recharacterising intra-group licensing arrangements conflicts with the OECD Transfer Pricing Guidelines. #TransferPricing #CorporateRestructuring #SvalnerAtlas #SwedenTax #OECD #ITR

Several recent South Korean transfer pricing cases have established clearer judicial standards. These precedents emphasize the need for robust comparability analysis and stronger functional and economic evidence. Yulchon’s tax partners offer practical insights for multinational companies navigating these heightened requirements. #TransferPricing #Yulchon #KoreaTax #TaxCompliance #InternationalTax #ITR

For high value-adding services, standardized cost-plus models are increasingly disconnected from the actual value generated. Michael Cedercrantz of Skeppsbron Skatt discusses the anticipated updates to Chapter VII of the OECD Transfer Pricing Guidelines and how pricing methods must align with value creation rather than just a local cost base uplift. #TransferPricing #ValueCreation #SkeppsbronSkatt #OECDGuidelines #IntraGroupServices #ITR

Canada's Bill C-15 has introduced the most significant changes to the nation's transfer pricing regime since 1997, eliminating the formal distinction between pricing adjustments and nonrecognition and replacement. Discover what these expanded rules mean for taxpayers, recharacterisation risks, and the newly shortened 30-day documentation response period. #TransferPricing #CanadaTax #TaxReform #TaxpayerCompliance #Recharacterisation #ITR