The number of transfer pricing disputes is increasing. GE, Starbucks, Apple, Facebook and Nike are just a few examples of the many MNEs that are, or have been, subject to disputes around the world. Moreover, the counter-parties of these disputes are not just tax authorities, but also supranational organizations, such as the European Union. And it is not just large-listed MNEs that face scrutiny. Smaller MNEs are subjected to the same legislation after all.
This short article first discusses the nature of transfer pricing disputes. It then lists the most common dispute areas, before moving on to a few basic measures you can take to limit your risk on a transfer pricing dispute. [Read more…]