Transfer Pricing 2026

EUROPE-WIDE Trends and Developments Contributed by: Munshya Mupela, Semra Altıntaş, Shirley Li and Joyce Lo TPA Global TPA Global is an independent tax advisory firm specialising in transfer pricing and international tax, which operates through a global network covering 60 countries and supported by over 5,000 tax profes - sionals worldwide. Headquartered in Diemen (Am - sterdam area), the Netherlands, the firm works close - ly with alliance partners across Europe, the Americas, Asia‑Pacific, and other key regions to support multi - national clients on a cross‑border basis. TPA Global’s core expertise includes transfer pricing documen - tation, international tax structuring, and valuation

Europe

and value chain analysis, complemented by closely related services in tax technology, digital tax trans - formation, and global tax controversy and litigation support. Recent work includes advising multinational groups on global and local transfer pricing docu - mentation, international tax structuring projects, and valuation and value chain analyses. The firm also pro - vides support on digitalisation initiatives and tax con - troversy matters, enabling clients to achieve compli - ant, efficient and future‑proof tax operating models.

Authors

Munshya Mupela is a senior associate at TPA Global with strong expertise in transfer pricing, accounting and tax controversy. In this role, Munshya supports multinational clients in preparing

Shirley Li is a senior associate at TPA Global with experience in transfer pricing and international tax matters. She has an academic background in tax controversy and international business, with a particular focus on

transfer pricing documentation and assists with controversy‑related matters. By combining solid technical transfer pricing knowledge with financial and accounting expertise, Munshya delivers practical, well‑substantiated solutions for cross‑border transactions and compliance with international tax regulations.

cross‑border regulations, and she is qualified as a lawyer in China. Shirley supports multinational clients with transfer pricing documentation, benchmarking analyses, and functional and financial analyses, helping to ensure compliance with OECD Guidelines and local regulations.

Joyce Lo is an associate at TPA Global with professional experience in audit, accounting, tax and transfer pricing. In her role, she supports multinational clients with the preparation of transfer pricing

Semra Altıntaş is an associate at TPA Global with a strong legal and tax technology background, supporting multinational clients at the intersection of law, tax and digital transformation. She is a licensed

documentation, benchmarking analyses and valuation for cross‑border transactions. Joyce is involved in transfer pricing compliance projects and broader international tax engagements, applying her combined audit and accounting background to deliver practical, technically sound analyses in line with OECD Guidelines and local regulatory requirements.

attorney in Turkey and has experience in international business taxation, corporate and commercial law, and data protection. In her role, Semra advises on tax‑related legal matters, supports tax technology and digital compliance projects, and helps align legal requirements with technology‑driven tax processes.

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