Emerging Trends in Transfer Pricing
Article published in SAIT, Tax Talk Magazine, Issue 103 November/ December 2023
Transfer pricing (TP) disputes have always posed challenges to multinational enterprises (MNEs) and tax authorities. The interpretation and implementation of arm’s length principles, the backbone of TP regulations, have led to an increasing number of TP disputes across the globe. This article considers emerging trends, emphasising the critical role of TP expert witnesses in any TP dispute.
The significance of TP expert witnesses in TP disputes
A central theme in any TP dispute resolution process is the selection and preparation of a TP expert witness. Such an expert is often called upon to lend their expertise during the trial; however, their participation is required very early in the TP dispute process to aid in finding workable resolutions.
Selecting the right TP expert witness
The onus of proving the arm’s length price rests with the taxpayer. It is crucial to choose an expert who possesses the requisite technical knowledge and the capability to present findings credibly in a court environment. Whereas there are many TP specialists globally, only a handful have the experience to serve as an effective expert in such a setting. A list of key considerations in selection follows. >>> Click here to download the full article >>>
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PROGRAMMES IN INTERNATIONAL TAXATION
- Postgraduate Certificate – 6-month Course
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PROGRAMMES IN TRANSFER PRICING
- Postgraduate Certificate – 6-month Course
- Postgraduate Diploma – 1 Academic Year
- Master (MSc) – 2 years (dissertation only if you have an existing PG-D from I/I/T/F)
- Contact our Education Consultant, Ben Price, at tp@informaconnect.com or call him at +44 (0) 208 052 2710.
* All programmes are delivered by I/I/T/F Academy of Tax Law and validated and certified by Middlesex University, London. InformaConnect Ltd is the programme partner.
