US and European multinationals are facing a perfect storm on the tax front: complex OECD Inclusive Framework tax proposals, COVID-19 accounting and economic guidance, political tension, increasing trade barriers, limited resourcing for ever-expanding tax compliance burdens, and so on. How should MNE leaders approach solving their bilateral or multilateral tax and transfer pricing disputes? Traditional risk management and arbitration strategies such as MAPs and APAs can fail and multinationals may be forced to litigate to prevent worst case outcomes.
Based on real-life transfer pricing litigation and arbitration cases involving both European and American multinationals, the presenters will:
- Share their practical experiences about how typical TP-related tax disputes arise in Europe;
- Explain what red flags indicate a high probability that an audit will move to litigation stage;
- Discuss practical solutions and technical analysis complementary to traditional TP practice; and
- Present solutions to tax disputes.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
