Source: Taxation In Australia Journal Article
Published Date: 1 Dec 2022
Transfer pricing controversies often involve significant issues relating to the core profitmaking elements of an organisation. Such cases can be complex, time-consuming and expensive to resolve. By their nature, it is rare that transfer pricing disputes yield a single obvious outcome that clearly favours one of the parties. As a result, it is important that parties are alive to all dispute resolution avenues and that one avenue is not prematurely dismissed in favour of another. This article explores some themes to be borne in mind by practitioners engaged to assist clients with their transfer pricing disputes, and how to prepare such disputes, both for potential contested litigation and for reaching an eventual settlement.
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