Company audits and dispute resolution

Even though the various efforts at international level are aiming to harmonize the principles for assessing transfer prices, the existing recommendations and amendments still leave a great deal of room for interpretation and implementation in local law is inconsistent.

At the same time, the pressure on taxpayers in tax audits at home and abroad has increased significantly. The potential for conflict and the risk of double taxation continues to increase. This requires taxable companies to adopt a sustainable strategy and stringent approach in order to meet this challenge.

We support you in the substantive and formal defense of transfer pricing in the context of tax audits and any associated legal disputes and dispute resolution proceedings.

Our services include the following:

• The proactive development of audit strategies, taking into account various options for a possible dispute resolution,
• the preparation and support of proceedings based on the International Compliance Assurance Program (ICAP) and the European Trust and Cooperation Approach (ETACA),
• the planning, preparation and implementation of bilateral and multilateral Advance Pricing Agreements (APA),
• the preparation and support of tax audits, including the support of coordinated international external audits (joint audits) and simultaneous audits,
• the preparation and implementation of objection proceedings,
• the preparation, coordination and implementation of cross-border mutual agreement and arbitration proceedings (MAP, EU Arbitration),
• the preparation and support of tax court proceedings (FG, BFH) and
• support in criminal tax proceedings relating to transfer pricing.