Concluding a tax audit through settlement
In an audit focused on intra-group transactions, document submission and the statements in the minutes were managed under a single strategy; the post-report assessment and settlement stages were conducted with comparables analysis, and the case was closed.
What is written in the minutes is the fate of the case
The audit questioned whether the intra-group pricing was at arm's length.
Giving the statements in technical language and consistently would shape every subsequent stage.
Our Approach
Keeping the commercial objective at the centre, we broke the legal risks into measurable steps.
01 · Documentation Strategy
The TP (transfer pricing) documentation and supporting analyses were compiled.
02 · Record Management
The statements were given within a technical and consistent framework.
03 · Settlement
The negotiation was conducted by analysing interest and penalty scenarios.
Chronology
The main stages of the process.
A case closed without going to court
The audit was closed at the settlement stage with defensible documentation and a consistent statement strategy; the transfer-pricing documentation framework was made permanent.
- Consistent record and statement management
- A position grounded in comparables analysis
- A process closed by settlement
- A durable TP documentation framework
Services Involved in This Matter
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Related Areas of Expertise
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Sectors
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First we clarify the commercial objective, risk appetite, timeline, and the decision-makers' needs. We then break the work into legal analysis, document/contract structure, and implementation steps, and manage the process through a single point of contact.
Because of the legal profession's duty of confidentiality and client privacy, matters are anonymised. In a meeting, within the bounds of confidentiality, we can describe our comparable experience more concretely.
In a short preliminary meeting, we take in the objective, the available documents, the parties, the time pressure, and the critical risks. The scope, team, timeline, and fee model are then clarified.
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