Tax Controversy and Dispute Resolution services

Globally, the number of transfer pricing audits has been increasing rapidly in recent years, with a stronger focus on ensuring that companies have met transfer pricing requirements in their local jurisdictions. Our transfer pricing team can offer the following services to help you identify potential exposures, manage your risk, and help you resolve any conflicts that may arise with regard to transfer pricing.

Tax dispute avoidance techniques

Identifying potential transfer pricing exposure enables you to put policies and processes in place in order to avoid audits or disputes. PwC can conduct reviews of your documentation and intercompany agreements, analyse and identify your opportunities to reduce tax and penalty exposure, and recommend ‘best practice’ policies for your related-company transactions.

Tax audit management practices

PwC’s assistance in the process of a transfer pricing audit may reduce the risk of income adjustments and avoid escalation of more involved disputes. We can also help you in creating a strategic response towards the tax authority’s requests.

Tax dispute resolution alternatives

PwC’s transfer pricing professionals can work with you at both the global and local level, to implement practices that may reduce or eliminate the likelihood of prolonged disputes or litigation. Many of our professionals come to us from prominent positions in academia, industry and government. This highly strategic experience places PwC in a strong position to help you identify technical issues, analyse findings, prepare presentations, and assist in the resolution of any disputes. We can also assist with all aspects of your Advance Pricing Agreements (APAs) and Competent Authority negotiations.

For more information, please see PwC’s global website.