Transfer Pricing Services | Controversy & Dispute Resolution Support
SAJ Consulting – As tax authorities worldwide intensify transfer pricing audits and cross-border information exchange, transfer pricing disputes have become increasingly complex and high risk. Even well-documented intercompany transactions may be subject to significant adjustments if they are challenged by tax authorities. In this environment, effective transfer pricing controversy management is essential to protect a company’s financial position and maintain tax certainty.
Transfer pricing controversy and dispute resolution support focuses on providing both technical depth and strategic guidance throughout the entire dispute lifecycle. This begins at the tax audit stage, where transfer pricing adjustments are often proposed based on differing interpretations of functions, risks, or comparability. A thorough analysis of the tax authority’s position is critical, including a review of the audit findings, benchmarking methodology, and legal basis for the proposed corrections.
Based on this analysis, defensible technical positions are developed in line with the OECD Transfer Pricing Guidelines and applicable local regulations. This includes reassessing functional, asset, and risk (FAR) profiles, evaluating the appropriateness of transfer pricing methods applied, and identifying weaknesses in the tax authority’s economic analysis. Clear and well-structured written submissions are then prepared to articulate these positions in a manner that is technically robust and aligned with prevailing international standards.
Beyond the audit phase, professional support is provided during objections, appeals, and litigation processes. This involves strategic case management, coordination with legal counsel, and preparation of supporting documentation and expert analyses. Where applicable, assistance is also provided during discussions and negotiations with tax authorities, including mutual discussions aimed at achieving fair and consistent outcomes.
Effective dispute resolution support not only strengthens a taxpayer’s defense but can also reduce the likelihood of prolonged disputes and double taxation. By combining technical expertise with practical negotiation strategies, taxpayers are better positioned to manage transfer pricing controversies efficiently and with greater certainty.
SAJ Consulting – Transfer Pricing Services
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Facing a transfer pricing audit or dispute? Engage experienced transfer pricing specialists to defend your position, manage risks, and navigate complex controversy processes with confidence and clarity.
