2022 Baker McKenzie Joint Special Report: The Global Landscape of Transfer Pricing Controversy: Trends You Can't Afford to Ignore

Transfer pricing audits are increasing in number, complexity, and expense, all around the world.

As taxing authorities look for additional revenue after the Covid-19 pandemic, countries like the United States have provided them additional funding to bolster compliance by multinational enterprises, targeting investments in data analysis and artificial intelligence to increase transparency.

This Special Report — created with Baker McKenzie — shares best practices to help businesses navigate the complex and costly transfer pricing audit.

Topics include:

  • Resolving transfer pricing disputes
    • Pre-audit prevention
    • International Compliance Assurance Program
    • Settlement options
    • Litigation
  • Leveraging advanced pricing arrangements (APA) to prevent disputes
    • Three forms of APAs
    • Trends and benefits
    • Is an APA right for you
    • Best practices and jurisdiction-specific insights
  • Avoiding double taxation
    • MAP and arbitration overview
    • Procedure break down
    • Articulation with domestic litigation
    • Peer review
  • Global trends and developments
    • Coca Cola – U.S. controversy
    • Scope of transfer pricing litigation
    • Recharacterization of transactions
    • Selecting the best transfer pricing method
    • Intangibles, business restructuring, management fees

Download this complimentary report for insights to help strengthen your transfer pricing policy and mitigate risk.

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