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Dispute Resolution: Examination Defense and Mutual Agreement Procedure/Competent Authority

Deloitte works with clients to explore strategic opportunities to enhance global tax and treasury planning, by aligning the relationship between the taxpayer’s value drivers and income/cost streams to improve their effective tax rate (ETF). This can include supply chain and intellectual property strategies and global charges. Deloitte's services help integrate operational and tax planning in a way that allows clients to treat tax as another cost of doing business making strategic decisions on an after tax basis.

Global transfer pricing rules often require taxpayers to explain the economic foundation and results of their intercompany transactions. Deloitte's teams are composed of economists, lawyers, accountants and financial analysts who review clients’ internal data and leverage it with publicly available sources and original research to explain the economic foundation of underlying intercompany transactions. This includes reviewing risk allocations in intercompany arrangements within a meaningful industry analysis, deploying the methods and guidance provided in national tax rules and the OECD Guidelines.

Through their considerable experience, our transfer pricing professionals are uniquely in touch with the complexities of audit defense, tax treaty issues and international tax dispute resolution. Our combined knowledge of the issues, processes and competent authority functions around the world is unrivaled. We specialize in resolving all types of issues faced by multinational enterprises operating both within and outside the treaty network, and we have high credibility with government officials and current competent authorities around the world.

Our Competent Authority (CA) services span three key areas:

  • Strategic planning. As you pursue global expansion or business transformation, you must anticipate both the obstacles to and the opportunities of your plan. We help you plan and prepare so that you can enter new markets with confidence and accelerate problem resolution more effectively.
  • Compliance. We help you ensure that your enterprise is in compliance with double taxation treaties around the world, so that you avoid costly penalties and noncompliance headaches associated with transfer pricing audits.
  • Dispute resolution. We can help you manage the appeal process when issues arise, including negotiation with relevant competent authorities and assistance with litigation, if necessary.

We can also help you obtain prospective tax relief, including an Advance Pricing Agreement.

Learn more about Deloitte's Competent Authority Services.

As used in this document, “Deloitte” means Deloitte Tax LLP. Please see www.deloitte.com/us/about for a detailed description of the legal structure of Deloitte LLP and its subsidiaries. Certain services may not be available to attest clients under the rules and regulations of public accounting.

 

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