Transfer pricing audit defence requires careful preparation, proactive engagement with the tax authorities and effective advocacy of the positions taken. We support companies from the first information request through to resolution.
The service covers:
- Review of information requests and preparation of structured, internally consistent responses
- Analysis of the methodology applied by the tax authority in assessing arm’s length prices or margins, and technical commentary identifying where it departs from the applicable local transfer pricing rules, the OECD Transfer Pricing Guidelines, or the facts of the transaction
- Development of the defence strategy and the sequence in which positions are presented
- Supplementary economic analysis where the existing documentation does not fully support the position taken
- Attendance at meetings with the tax authorities alongside your representatives
- Mutual Agreement Procedure under the applicable treaty, and corresponding adjustments to eliminate double taxation
- Arbitration under the EU Tax Dispute Resolution Directive
- Quantification of penalty exposure and advice on mitigation
We also provide second opinions on existing documentation under challenge — whether the position can be defended as drafted, and what additional analysis or evidence would strengthen it.
Get in touch
Send us a message
Tell us about your intercompany transactions and we’ll be in touch.