Transfer Pricing Controversy

Multinational enterprises (MNEs) today face an increasing number of transfer pricing disputes, which may result in major legal and financial consequences for their various stakeholders.

This issue of the Fall 2023 Transfer Pricing Forum explores the transfer pricing controversy to gain the unique perspectives of practitioners from each country as they answer the following:

1. How do the tax authorities select taxpayers for audits for transfer pricing cases and what are their focus areas that could lead to transfer pricing audits?
2. Which approaches are followed by the tax authorities during transfer pricing audits and what are the key elements considered by courts when deciding on transfer pricing related disputes?
3. In relation to tax audits How can MNEs best prepare for potential disputes, and what can they do to mitigate the risks of future disputes?

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