Tax certainty and dispute prevention
Ruling, APA and risk-review support to reduce uncertainty before disputes arise.
The best transfer pricing disputes are often the ones that are prevented. We help clients identify risk areas, strengthen evidence and engage with tax authorities where appropriate to obtain greater certainty before a challenge arises.
Why this matters
Transfer pricing adjustments can lead to double taxation, penalties, interest, management distraction and long-running disputes. A proactive strategy can help reduce uncertainty, especially for material transactions, restructurings, financing arrangements or business models that are likely to attract attention. Tax certainty is not only a legal outcome – it is also a governance and risk management objective.
How we help
- Perform risk reviews: identify transactions, entities, margins, documentation gaps and economic analyses most likely to trigger questions.
- Stress-test documentation: review whether files, benchmarks, agreements and financial outcomes can withstand tax authority scrutiny.
- Support rulings and APAs: prepare technical analyses, economic support and submissions for unilateral, bilateral or multilateral certainty processes where appropriate.
- Prepare for tax authority engagement: develop key messages, evidence packs, transaction summaries and response strategies.
- Coordinate internationally: align positions across jurisdictions and anticipate how one authority's view may affect another.
- Support cooperative or multilateral processes: prepare for cooperative compliance such as the Belgian Co-operative Tax Compliance Programme (CTCP), OECD ICAP risk assessment or similar processes where relevant.
Typical deliverables
- TP risk assessment report
- Documentation stress-test and action plan
- APA or ruling feasibility assessment
- APA/ruling submission support
- Tax authority engagement strategy
- Evidence pack and Q&A preparation
- International coordination plan
Typical triggers
- Material or complex intercompany transactions
- Business restructuring or IP migration
- Recurring losses or margin volatility
- Planned APA or ruling request
- Preparation for audit or cooperative compliance review
- Need to reduce double-taxation risk
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