Dispute Resolution

Transfer pricing is one of the major issues facing multinational corporations today. Tax authorities globally are devoting more and more resources into auditing cross border related party transactions in order to ensure such transactions are conducted at an arm’s length price. As the determination of transfer prices is subjective, tax authorities are aggressive in determining what they believe constitutes an arm’s length price in order to collect additional tax.

Altus Network has broad experience in assisting clients both when disputes arise. With a global presence, Altus Network can ensure your rights are protected in both the country the audit is being conducted as well as the country that is party to the related party transaction.

  • Audit defense – assistance during the audit
  • Appeals – assistance after the audit with local appeal options
  • Competent authority – assistance after the audit to relieve double taxation pursuant to tax treaties
  • Litigation – assistance as expert witnesses before the courts

To prevent disputes, we have substantial experience with:

  • Advance Pricing Arrangements – assistance in obtaining prospective certainty on your transfer pricing policies
  • Voluntary Disclosures – assistance in filings and negotiations with tax authorities to avoid penalties