Representation before tax authorities and Courts

Multinational enterprises (MNEs) have been facing disputes on tax and/or transfer pricing with tax authorities since their very inception. Over the course of time, a wide variety of instruments have been developed in order to address these disputes. In the light of Base Erosion and Profit Shifting (BEPS) Action Plan the importance of such instruments has increased as Action plans proposed substantial amendments to the OECD TP Guidelines and to the transfer pricing system as a whole.

Being In Control

In order to be able to avoid and/ or resolve disputes, as a first step, MNEs need to be “in control” of their tax matters while running their operations. Being “in control” consists of completion of the following three activities:

  • Creating a proper and timely risk management structure;
  • Running a compliance cycle; and
  • Dealing pro-actively with dispute resolution.

Your Key Benefits

  1. Pro-active risk management set up
  2. Identification of potential disputes at every level of the value chain
  3. Robust control of the audit procedure
  4. Prepared for dispute resolution at all stages and in all countries of operation
  5. Better and efficient control of your operations

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Transfer Pricing Associates introduces TPA BEPS Desk. If you have any questions, or need more detailed advice on any aspects of BEPS related issues, please get in touch with us. The TPA Global network has alliance partners throughout the world, and the network can provide multi-disciplinary approach on today's critical transfer pricing challenges faced by multinational enterprises.

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