Resolve: TP Controversy

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

We have Transfer Pricing people, some of whom used to be with the tax authorities, who are well-versed in helping clients navigate transfer pricing and diverted profits tax enquiries from HMRC. Together we have experienced and concluded a huge number of enquiries and we have built up considerable expertise in this difficult area. We also spend a great deal of time resolving double tax issues through Mutual Agreement Procedures and Advance Pricing Agreements. Whether we are preventing disputes from arising or resolving them, Transfer Pricing controversy expertise is an integrated part of the Deloitte Transfer Pricing service delivery.

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 contact

Eddie Morris

Eddie Morris


Eddie served for 12 years at HMRC’s International Head Office on transfer pricing controversy cases before joining Deloitte. As well as interacting with HMRC at a policy level, he helps clients with c... More