Dispute resolution strategies

Defending your transfer pricing policies during an audit dispute

Multinational organizations need to ensure their transfer pricing policies meet regulatory requirements and must be ready to mount an audit defense, if necessary.

Transfer pricing audits can be time-consuming and drain internal resources. Taxpayers with intercompany cross-border transactions should have a coordinated dispute resolution strategy in place that includes managing the audit process.

Significant tax implications can make resolving potential disputes with tax authorities extremely difficult. As a result, in-depth knowledge of the CRA’s policies and an understanding of the options available to minimize disruptive audits are vital components of any effective dispute resolution strategy.

How PricewaterhouseCoopers can help

PwC’s diversified network, domestically and globally, provides effective representation through all phases of dispute resolution: audit and appeal processes, competent authority negotiations, Advance Pricing Arrangements (APAs), voluntary disclosures, and litigation.

Our multidisciplinary team:

  • Develops dispute strategies that provide maximum benefits to multinational organizations
  • Specializes in defending transfer pricing policies on audit
  • Presents sound negotiable positions through the APA and competent authority processes

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