A surge in transfer pricing audits and examinations around the world is leading to an unprecedented level of disputes and controversies impacting companies across the globe. These investigations can be lengthy and expensive if not dealt with efficiently, and can result in significant adjustments and penalties for non-compliance which can be very severe. There can also be reputational damage arising from the surrounding publicity.
The emerging perfect storm of transfer pricing audits and disputes focuses on several important global dispute resolution topics, including:
- recent developments involving the taxation of PEs;
- recommended improvements to APAs and Mutual Agreement Procedures (MAPs) around the world; and
- best practices in the global dispute resolution arena.
This new era of global tax audits and disputes raises numerous challenges for companies and their advisors—are you prepared for the storm?
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