Tax Controversy

No matter how diligent you are in analyzing and documenting your transfer pricing, if you are engaging in significant business that crosses national borders, the odds are high that the pricing of those transactions will be disputed by a tax authority at some point.

Your company may face double taxation if taxing authorities on either side of a transaction disagree with your transfer pricing policy. We can help you reduce this risk through the use of the Competent Authority process. Tax authorities of the two jurisdictions can negotiate a mutually agreeable solution to the adjustment so that you are taxed only once on your income from the cross-border transaction. We can assist you in working with the Competent Authorities of the two countries to ensure that they understand your business, the transactions and the basis for your transfer pricing methodology.

Additionally, our professionals have significant experience in dealing with transfer pricing examinations, administrative appeals and tax litigation. Due to our broad depth of experience, we know first-hand the perspective of the IRS, the corporate taxpayer and the third-party tax advisor.

These are all roles we have assumed in dealing with various issues of transfer pricing dispute. No matter what type of dispute you are dealing with, we will provide you with the specialist support you need, and we will assist you in dealing directly with the appropriate authority.