Transfer pricing perspectives

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This publication focuses on the growing number of global disputes and the trend of dispute avoidance. The publication includes articles covering complex topics such as binding arbitration, best practices in global dispute resolution, permanent establishments, advanced pricing agreements and triangular cases.

The report, which features analysis of client engagements across the PwC global dispute resolution network, shows that the number of transfer pricing disputes increased by 152% between 2006 and 2007 (indexed to 2005 data). As governments have stepped up their efforts, the number of transfer pricing disputes has soared.

The most dramatic increase occurred in the area of transfer pricing audit defence, where the number of projects increased by 181% globally (indexed to 2005 data). As tax audits are typically the first phase in a transfer pricing dispute, the report highlights that this upward trend will only continue.