Assessing a multinational's global business model is no longer an optional exercise. The global economic environment is characterized by continuous improvements in technology, an urgency to adopt and implement best practices and processes, and the potential for legislative change such as Base Erosion Profit Sharing (BEPS), a movement that will address concerns surrounding current principles of national and international taxation that is failing to keep pace with the global nature of modern trading and business models. Our focus is practical, early resolution, but we have the capabilities to go the distance where litigation makes sense. Leverage the powerful combination of former senior CRA officials, top tax litigation lawyers, and pre-eminent specialists in all subject areas of tax, collaborating at all stages to deploy the optimal dispute resolution strategy. Deloitte takes an integrated approach to resolving transfer pricing disputes in the MAP process. Effective and efficient explanations of business transfer pricing policies include early involvement of an experienced global team that has practical experience with all levels of the tax authority process, from proposed adjustments by field agents, through Advance Pricing Agreements, administrative appeals, litigation and the Mutual Agreement Procedure (MAP) process. ![]() ![]() Often it is the actions and responses in the initial stages of a tax authority enquiry or interview that affects the course or outcome of a transfer pricing examination. Dispute resolution: Examination defense and mutual agreement procedure/competent authority
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