Support during tax audits, resolution and avoidance of tax controversy

Tax auditors are increasingly turning their attention to transfer pricing issues. PwC’s transfer pricing experts assist companies with tax audits and tax court proceedings. They also have the necessary experience to advise companies on the conclusion of advance pricing agreements (APAs) and on mutual agreement or arbitration procedures. In doing so, they can draw on the experts from the global PwC network.

Tax audits and tax court proceedings

When an international company faces a tax audit in its home country or abroad, transfer pricing is often one of the key areas of interest from the tax authority. Some local tax authorities are known for the tenacity with which they pursue questions about transfer pricing and documentation requirements. This makes efficient audit management all the more important.

PwC Germany’s transfer pricing specialists work closely with the international PwC network. They have many years of experience in defending a wide variety of complex transfer pricing systems in tax audits. They are experienced in dealing with the local tax authorities. Specially trained experts assist in difficult negotiations.

The members of PwC’s German transfer pricing team represent clients in court cases on transfer pricing issues.

Advance pricing agreements (APAs)

In order to achieve legal certainty, companies can in many countries apply for a unilateral, bilateral or multilateral advance pricing agreement (APA) with the local tax authorities. Critical to the successful conclusion of an APA are technical expertise, knowledge of the requirements specific to the tax authorities of the countries involved and professional project management. PwC’s experts provide just that.

Mutual agreement and arbitration procedures

A domestic or foreign tax audit that results in adjustments to transfer prices and thus taxable income may lead to double taxation. In such cases, the taxpayer can usually initiate a mutual agreement or arbitration procedure in order to avoid double taxation.

The transfer pricing experts at PwC Germany can draw on experts from PwC’s international Tax Controversy and Dispute Resolution experts group. These experts are specialised in dispute resolution, the negotiation of APAs and mutual agreement procedures.