Resolve: Confidently manage interactions with the global tax authorities

Lower your international transfer pricing risk profile

We are in a time of unprecedented change in the global tax landscape, resulting in continuous uncertainty—compounded by increased scrutiny from revenue authorities and the media. This intensifies the spotlight on tax leaders. Our transfer pricing controversy practice is here to help.

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
The transfer pricing controversy services information sheet

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


Martin Rabenort

Martin Rabenort


Martin Rabenort is a partner in Deloitte’s Dutch Tax & Legal practice. Besides that, Martin sits in the Tax Management Consulting (TMC) team. That team helps clients with Global Compliance & Reporting... More

Frederike Manzoni

Frederike Manzoni


Frederike Manzoni is a partner in Deloitte’s FSI practice and resident in our Amsterdam office. Frederike advises clients mainly on M&A, real estate and financial services and assists tax payers when ... More