The emerging perfect storm of transfer pricing audits and disputes
Today’s multinational corporations (MNCs) are facing the most challenging tax environment in history, because of a combination of four global forces converging to create a 'perfect storm'. The unstable environment created by these forces is resulting in a substantial increase in the number and size of transfer pricing audits, adjustments and disputes. This new environment places a premium on audit and dispute avoidance techniques. This paper discusses these four global forces and looks at proactive steps, including resolution techniques, MNCs can take to weather the storm.