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Energy multinationals have complex, international supply chains that contract a host of specialist companies in the process of bringing vital commodities to market, making intellectual property attribution ambiguous. In this primer, Deloitte’s Nick Gaudioso, Randy Price, Nadim Rahman and John Wells give an overview of the energy excavation and production process to understand the tax ramifications.

Transfer pricing (TP) litigation surrounding the energy and resources (E&R) sector has increased drastically over the past two years. While determining the owner of the commodity price risk has drawn increased attention, Deloitte’s Mark Barker and Aengus Barry discuss how tax authorities predominantly employ the comparable uncontrolled price (CUP) method in any TP dispute.

In conjunction with International Tax Review, Deloitte Touche Tohmatsu is pleased to present the 2019 Transfer Pricing Energy and Resources guide, a collection of industry thought papers produced by Deloitte member firm transfer pricing (TP) professionals in the energy and resources (E&R) industry.

Energy has always been one of the most dynamic and politicised industries in trade.

Multinational companies face the challenge of how to restructure their intellectual property (IP) in an increasingly uncertain world. Taxpayers can voice their concerns anonymously in International Tax Review’s IP survey.

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.

Offshore marketing hubs are becoming increasingly commonplace for Australian resource firms in Asia. Deloitte’s John Bland and Milla Ivanova discuss what factors may trigger increased regulatory scrutiny for a multinational under the Australian Taxation Office’s (ATO) risk ratings.

Volatile oil markets in 2018 presented significant challenges to Canadian exporters, but a shortage in natural gas production globally presented a complimentary opportunity. Deloitte’s Andreas Ottosson and Markus Navikenas discuss the transfer pricing implications.

Energy companies using an asset-backed trading (ABT) model can hedge against volatile markets by better controlling their supply chain, but this can also trigger new transfer pricing issues. Deloitte’s Nick Pearson-Woodd and Marius Basteviken discuss.

The OECD has issued new guidance on applying the profit-split method (PSM) in the energy and resources (E&R) sector. But will this see an uptick in its use? Deloitte’s Mark Barker and Aengus Barry discuss.