Transfer Pricing Audit Guidance

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.