Global Transfer Pricing Controversy in 2026: Navigating Audit Trends and Financial Transactions

In today’s volatile economic environment, getting intercompany financial transactions right has never been more critical.

Join S&P Global Market Intelligence, KPMG, and Grant Thornton Greece for an exclusive, closed-door fireside chat on how to navigate the growing level of regulatory scrutiny, the divergence in OECD guidelines implementation, and rapidly shifting credit conditions.

This session will provide tax, finance, and transfer pricing professionals with actionable strategies to confidently support intercompany interest rates, guarantee fees, and cash pooling structures.

We will unpack the latest global audit trends—from the IRS to European and LatAm tax authorities—and share best practices for robust scoring, benchmarking, and evidencing parental support.

Do not miss this opportunity to strengthen your approach, avoid the "audit lottery," and stay ahead of regulatory changes.

Key Topics of Discussion:

• The Global Regulatory Landscape: Connecting the dots between European Tax Authority expectations (post-IOTA Assembly) and the IRS’s massive increase in audit activity.
• The "Rating" Controversy: Bridging the risk gap between the IRS’s strict preference for standalone credit ratings and the OECD Chapter X push for implicit/parental support.
• Strengthening the Evidence Pack: Best practices for documenting scoring and benchmarking, and how tax authorities (e.g., Brazil, Australia) are using data analytics to challenge lender substance.
• Specialized Finance & Thin-File Entities: Defensible strategies for assessing debt capacity and credit risk for startups, Real Estate structures, and Project Finance SPVs lacking historical financials.
• Cash Pools & Market Dynamics: Heightened scrutiny around guarantee fees and companies passing central bank interest rates onto cash pool arrangements.

Speakers

Rafael Castro

Senior Credit Product Specialist - Credit & Risk Solutions
S&P Global Market Intelligence

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Sayantani Ghose

Partner, Economic & Valuation Services
KPMG US

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Elina Litsa

Partner, Deals Services
Grant Thornton Greece

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