Resolve: Confidently manage interactions with the global tax authorities

Why does controversy arise?

The continued reform of the international tax landscape has resulted in increased demands for transparency:

• Tax authorities are now gaining unprecedented access to public data, while subjective interpretation of the information by the tax authorities is making many multinationals uncertain about what risks they are exposed to.
  
• Intellectual property, permanent establishment, and intragroup financial arrangements also introduce a layer of complexity that is, at best, susceptible to broad interpretation.
• Many multinationals still lack sufficient infrastructure to address enhanced cross-border cooperation, including joint audits

Controversy services

Deloitte's transfer pricing specialists have worked with many multinational companies to manage their transfer pricing issues–particularly the risk of double taxation–on a prospective basis. From preventing disputes, to managing and resolving disputes with the tax authority, we can help you manage these issues.

Dispute prevention

We can assist with:

• Planning and preparation to minimize disputes
• Documenting and preparing evidence and defence files
• Reviewing and finalizing global strategic controversy awareness policies
• Bilateral and multilateral advanced pricing agreements (APAs)
• Advanced rulings and unilateral APAs
• Pre-transaction engagement with tax authorities
• Ongoing proactive engagement with tax authorities

Dispute resolution

Should an inquiry arise, however, Deloitte’s transfer pricing specialists can help with:

• Transfer pricing inquiry handling and closure
• Global inquiry process tracking
• Negotiation with tax authorities
• Analysis, economic and technical support
• Appeal and litigation support
• MAP and arbitration support
  

Key contacts