Our support to controversy embeds Communication actions (Master and Local File, internal toolkits, CbCR) as well as support in the economic aspects of Controversy such as in Audits, Mutual Agreement Procedures and Advance Pricing Agreements.

The latest years Tax and Transfer Pricing have evidenced the increased need for companies to develop proactive Controversy measures, sometimes pegged with Strategy and Planning activities. Controversy management starts in our view with the supporting documents to your policies, and then unfolds into Audit management and dispute resolution procedures (MAPs and APAs), each requiring a specific approach. We can collaborate with your organization to ensure Controversy readiness and during Controversy phases.

Controversy READINESS

  • Production of a value chain Master File document that will review the value drivers of your industry, your company and its organization, deploying high level and accessible economic analysis to support your prevailing transfer pricing models
  • Risk assessment within your Country by Country Report and production of narrative linking your CbCR to your Master File and your Tax Policy
  • Review of Local Files narrative, articulation and data production to ensure consistency across the board
  • Data availability: simple improvements can ease the life of your teams while in audit and relieve global teams on data processing and duplication.
  • Audit management protocols: rules of engagement between Global, Regional and Local teams in terms of audit management, with clear escalation procedures (bearing in mind that very often audits are not only handled by Tax trained persons)
  • Communication toolkits: scrutiny on tax is not limited to tax administrations anymore, and your Finance and Tax correspondents must be ready to communicate on tax policies. We can help you to deliver communication platforms.

Controversy MANAGEMENT

  • Audit support: we can support your organization on the deployment of economic transfer pricing analysis (functional analysis, economics and financial analysis) to sustain your position during a tax audit.
  • Advance Pricing Agreements: applying for an APA should be considered with care, from a technical and tactical standpoint, based not only on the merits of the case, but also on the possibility of different outcomes. We support your teams in this assessment.
  • Filing preparations: because each MAP has its own past, and because each APA has its own objectives, we believe that each filing should already embed a risk management component, and the emphasis of your file should reflect such features.
  • Negotiations facilitation: during audits, MAPs or APAs, a mutual understanding of facts and circumstances is key, and we know that such task is not the easiest when it comes to economic analysis. We help your organizations on presentations and during negotiation meetings with the tax administrations (scenario analysis, data modeling, viable position alternatives when applicable).

Just started to envisage Controversy readiness actions? Already embarked in an Audit or an international procedure or thinking about it? Contact us, we can provide you with insights from our own field experience.

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