Transfer Pricing Controversy

How PwC can help

Defence and dispute resolution

Fiscal demands on developed and emerging countries have placed considerable pressure on governments to raise revenue and prevent the erosion of their tax bases. Governments worldwide are cooperating as never before to share taxpayer and industry information, assist other countries with document and information requests, and participate in separate multi-country audits (including "simultaneous" examinations). Some countries are even considering the concept of "joint audits" where a single audit team--comprised of government tax inspectors and auditors from two or more countries--examines a specific taxpayer. At the same time,multinational corporations (MNCS) are experiencing increasingly complex regulations, heavy penalties, and transparency and disclosure issues.

We work closely together with our Tax Controversy and Dispute Resolution team in case of disputes, tax audits or information request relating to transfer pricing. We can assist in dealing with transfer pricing disputes involving two or more territories through the various dispute resolution procedures.

Advance Pricing Agreements

To reduce uncertainty on a prospective tax position, we can assist in obtaining Advance Pricing Agreements (APAs) from the tax authorities in Luxembourg. In addition, where a multi-country approach is more appropriate, we can assist in obtaining multilateral APAs.

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