As tax authorities become more knowledgeable, transfer pricing audits have increased in complexity. With BEPS, tax authorities have obtained more regulatory power and easier access to information than before. Potential disputes typically start with (standard) questionnaires send out by the tax authorities. Being able to answer these questions “correctly” requires full understanding of the case at hand from a transfer pricing perspective. Answers that do not align with existing transfer pricing documentation or that are inconsistent with accounting data or historical events may raise more questions and may potentially lead to tax adjustments.
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