In the light of Base Erosion and Profit Sharing (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.
How to be “in control” of your disputes
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 propoer and timely risk management structure;
- Running a compliance cycle; and
- Dealing pro-actively with dispute resolution.
How to prepare for an audit
A company that does not perform all of these activities is deemed to be not “in control” of its tax function. Therefore, it is likely to be subjected to an audit and subsequent adjustments/penalities.
Mere compliance with the obligations is not enough to keep the companies from avoiding disputes with tax authorities; in fact, meer compliance and no pro-active prevention of disputes can result in the effective tax rate of the company being raised by 10% – 20%. TPA Global has developed a thorough mechanism on how to address the increasing number of disputes.
Types of disputes in the value chain of an MNE
As a first step, TPA Global has framed the series of disputes that arise at various stages in the value chain of a company and the various dispute avoidance/resolution techniques that can be used appropriately at every stage:
Stages of dispute avoidance and resolution
TPA Global offers support in respect of the following controversy management instruments to prevent and/or resolve disputes with tax authorities:
What are your key benefits?
- Pro-active risk management set up
- Identification of potential disputes at every level of the value chain
- Robust control of the audit procedure
- Prepared for dispute resolution at all stages and in all countries of operation
- Better and efficient control of your operations