Conducting a Transfer Pricing Trial (eBook)

Transfer pricing disputes are increasingly prevalent as tax authorities seek to maximize tax collections from multinational enterprises (MNEs). Having participated in numerous transfer pricing trials, I felt it was time to document my journey and insights as a guide for others embarking on this challenging path.

This is in the form of a new book titled Conducting a Transfer Pricing Trial.

The book draws on my experiences with numerous transfer pricing trials across multiple jurisdictions and provides practical strategies for preparing and defending transfer pricing positions in court.

I have been working on this book for 18 months and it is currently in a pre-release state, with a beta version available immediately. It will be concluded by October 2024.

Conducting a Transfer Pricing Trial serves as an essential resource for tax professionals, MNEs, and legal practitioners involved in transfer pricing disputes. It ensures that they are well-prepared to defend their positions in an increasingly stringent tax landscape.

Click here to download the sample INDEX of the book

Why This Book Matters

It comes at a critical time when global tax authorities intensify their scrutiny of MNEs. As cross-border transactions become more complex, the need for detailed documentation and defence strategies in transfer pricing disputes has never been more crucial.

Understanding the Transfer Pricing Trial Process

The book offers a detailed walkthrough of the stages of preparing for and conducting a transfer pricing trial. From assembling a legal and expert team to developing a compelling case theory and dealing with the intricacies of cross-examination, we try to leave no stone unturned.

Key topics include:

  • Pre-Trial Preparation: How to review transfer pricing documentation, align it with OECD guidelines, and build a trial strategy.
  • Opening Statements: Structuring persuasive opening remarks that outline your key arguments and set the stage for a successful defence.
  • Expert Testimony: How to effectively present expert witness testimony and navigate the complexities of expert cross-examinations.

The ABD vs. CSARS Case

One of the standout sections of the book is the analysis of ABD vs. CSARS, a case involving the South African Revenue Service (SARS) and an African multinational. The case underscores the challenges MNEs face when defending transfer pricing policies in developing countries where tax authorities often lack the experience or resources to fully grasp the nuances of complex international transactions. This case is essential reading for anyone involved in cross-border tax disputes.

(Click here for to read my summary of the case).

Special Pre-Order Offer

We have a special pre-order price of $99.00. This is a 50% discount off the final release price, making it an affordable resource for professionals looking to stay ahead of the curve in transfer pricing litigation.

PRE-ORDER THE BOOK FOR $ 99.00 ONLY


What colleagues have said about the Dr Daniel N Erasmus

Dr. Daniel Erasmus has handled numerous tax disputes, but focuses specifically in the challenging environments of developing tax jurisdictions. His in-depth knowledge of international tax law and transfer pricing practices positions him as one of the leading experts in the field.

And

His legal acumen, coupled with his extensive courtroom experience, is distilled into this book, offering practical advice for navigating complex tax trials. Whether it’s understanding the nuances of the arm’s length principle, presenting expert testimony, or managing documentary evidence, readers will gain valuable insights that can be applied in real-world scenarios.


Related Articles