Transfer Pricing Dispute Prevention and Resolution

Transfer Pricing Documentation

In today's complex tax environment, businesses face increasing scrutiny from tax authorities. With a heightened focus of Serbian Tax Authorities on transfer pricing compliance, companies must navigate requirements such as contemporaneous transfer pricing documentation. 

Facing tax disputes can be one of the most challenging experiences for any organization due to the uncertainty and high stakes involved. It is crucial to manage these disputes with expertise and precision. Our dedicated team of transfer pricing and legal specialists offers effective, practical solutions to help clients manage and resolve tax disputes. 

While tax audit can be intimidating, it can be easier with proper preparation and the right advice. We provide comprehensive support, from prevention by strengthening your position through assisting during tax audits to supporting clients in the appeals and court process.

Pre-audit prevention phase

Our services:

  • Assessment of your current compliance position by reviewing the existing transfer pricing documentation and policies and by providing a heatmap of potential risk areas and compliance gaps;

  • Assistance in transactional due-diligence to identify tax audit and controversy risks and exposures;

  • Employee audit readiness assessment - Assessing your employees’  understanding of transfer pricing policies and positions, available supporting documentation and resources and audit process itself;

  • Tailored training programs based on the identified gaps or specific needs of your team, covering transfer pricing principles, deep dive into company’s TP documentation, audit processes and importance of proper communication.

Benefits:

  • Improved readiness for tax audits through proactive identification of risk areas.

  • Better understanding of potential impacts, allowing for preemptive risk mitigation and improvement of the current position.

  • Reduced likelihood of adverse audit outcomes through enhanced handling of audit procedures.

  • Mitigation of risks through well-prepared personnel serving as the first line of defense.

Audit examination and resolution phase

Our services:

  • During the audit, we will: 

    • Review the documents in order to assess the areas of potential risk and help with building a defence strategy and documentation;

    • Train the staff responsible for tax affairs to deal with the tax officials in an efficient and safe manner, develop their understanding of the audit process and available legal instruments;

    • Provide ongoing support on the spot, by assisting in preparing relevant documents and providing explanations to the tax officer conducting the audit;

    • Expert representation before the Tax Authorities.

  • Post audit, we will:

    • Provide support in further procedural or legal action in case of a tax assessment upon completion of the audit;

    • Provide assistance in identifying the optimal approach to be used in the litigation process and in drafting the appeal for you based on the best and most relevant arguments for the disputed scenario;

    • Support in implementing the most appropriate strategy that presents the strongest tax, legal and practical arguments to be used in drafting an appeal;

    • Expert representation before the Tax Authorities.

dispute prevention and resolution

Benefits:

  • Expert assistance and real-time support by both transfer pricing and legal experts

  • Ensuring potential risk areas or red flags are appropriately tackled upfront

  • Coordinated communication and consistency of information provided

  • Strategic dispute resolution and negotiation efforts aimed at achieving favorable outcomes, preserving financial and operational stability

Contact us

Dragan Draca

Dragan Draca

Partner, Tax Services, PwC Serbia

Mirjana Petkov

Mirjana Petkov

Director, Transfer Pricing Services, PwC Serbia

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