Transfer pricing controversy and dispute resolution

When transfer pricing questions become disputes, clients need both technical depth and practical controversy management. We support clients during tax audits, information requests, technical discussions with tax authorities, audit defence, mutual agreement procedures and similar double-tax relief cases.

Why this matters

Transfer pricing audits can be data-intensive, cross-border and time-consuming. Responses must be accurate, consistent and strategically managed. A strong controversy approach combines technical analysis, reliable evidence, clear communication and coordination between local and foreign advisors.

How we help

• Assess the audit position: review the facts, documentation, benchmarks, intercompany agreements, financial outcomes and authority questions.
• Develop the defence strategy: identify key arguments, evidence gaps, negotiation points and potential exposure.
• Prepare responses: draft responses to information requests, technical position papers and supporting analyses.
• Support meetings and negotiations: prepare client teams for discussions with tax authorities and support technical exchanges.
• Coordinate cross-border positions: align defence strategies where multiple jurisdictions are involved and assess double-taxation implications.
• Support MAP and relief processes: assist with mutual agreement procedure preparation, filing support and case management where relevant.

Typical deliverables

• Audit defence strategy and work plan
• Information request responses
• Technical position papers
• Benchmark review and rebuttal analysis
• Tax authority meeting preparation
• MAP support and double-tax relief analysis
• Post-audit remediation plan

Typical triggers

• TP audit or information request
• Proposed TP adjustment
• Double taxation risk
• Challenge to benchmark, method or tested-party selection
• Dispute following business restructuring or financing transaction
• Need to align Belgian and foreign defence positions