Transfer pricing: Global tax controversy and dispute resolution services

The last few years have seen a surge of transfer pricing audits, a trend that is not expected to slow down anytime soon. A decade ago, only a few countries had formal transfer pricing documentation requirements. In 2009, more than 60 countries did.

International Transfer Pricing 2013/14:

An easy-to-use reference guide covering a range of transfer pricing issues.
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Transfer pricing perspectives:

A collection of articles that discuss some of the significant policy and legislative changes taking place in transfer pricing.
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FSTP perspectives

PwC's bimonthly publication offers an insight into trends and developments in financial services transfer pricing.
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Our services include:

Tax dispute avoidance techniques 

You need to know whether and where any transfer pricing audit exposure exists. We can help you implement sound policies and processes that may provide a defensible model, and help safeguard against tax audits and disputes. We can conduct reviews of your documentation and inter-company agreements, analyse and identify your opportunities to reduce tax and penalty exposure, and recommend “best practice” policies for your related-company transactions.

Tax audit management practices 

We can recommend processes to manage your transfer pricing audits and examinations, which may reduce the risk of income adjustments and avoid escalation of more involved disputes. We can also help you craft a strategic response to taxing authority requests.

Tax dispute resolution alternatives 

We can work with you at both the global and local level to implement practices that may reduce or eliminate the likelihood of prolonged disputes or litigation. Many of our professionals come to us from prominent positions in academia, industry and government. This highly strategic experience places PwC in a strong position to help you identify technical issues, analyse findings, prepare presentations, and assist in the resolution of any disputes. We can also assist with all aspects of your advance pricing agreements (APAs) and Competent Authority negotiations.

Global strategic planning of tax audit and disputes 

We are well positioned across our member firms to help you develop a global strategy for avoiding or managing any future transfer pricing disputes or examinations. In addition to advising on the proactive use of APAs, we can recommend strategies consistent with your goals that utilise foreign tax credits, separate country net operating losses, foreign currency positions, tax holidays, and other tax attributes.

Tax risk management, analysis, and disclosure 

We can analyse your transfer pricing methodology and help you develop sound documentation policies and processes. These could in turn provide a defensible approach to safeguard against non-compliance penalties and other exposures. Our process also includes a comprehensive examination of any transfer pricing positions that may affect FIN 48 or other regulatory disclosures.