The prevention and resolution of tax disputes. Roughly speaking, that is the purpose of ‘Controversy and Dispute Resolution’. Like no other, Meijburg & Co can provide you with assistance and advice in disputes with tax authorities, and when you need more certainty in advance by means of an Advance Pricing Agreement (APA).
Controversy and Dispute Resolution: defensive or proactive?
There are two options for managing your Transfer Pricing risks with Controversy and Dispute Resolution:
1. Defensive
You meet the minimum requirements concerning Transfer Pricing documentation.
2. Proactive
You coordinate with one or more tax authorities in advance.
Double taxation
Assistance in the field of Controversy and Dispute Resolution may be required when tax authorities conduct audits into your business. Disputes and situations concerning double taxation may arise in relation hereto. Double taxation can be resolved, among others, by instituting a Mutual Agreement Procedure (MAP) or Arbitration Proceedings between two or more of the countries involved.
Always the right Transfer Pricing methods with APA
Do you want to ensure more security where your Transfer Pricing policy is concerned? Then you can obtain security in advance from the Dutch Tax Administration by means of an Advance Pricing Agreement (APA). This involves requesting the Tax and Customs Administration’s approval for the Transfer Pricing policy you are applying. APAs can be entered into with one or more tax authorities.
Good relations with the Tax and Customs Administration pay
APAs, MAPs and Dutch Tax Administration audits are all familiar territory to Meijburg & Co. And experience shows that the earlier we are involved in these processes, the more effectively we can assist you where Controversy and Dispute Resolution are concerned.
KPMG’s network and the multidisciplinary tax approach
In Controversy and Dispute Resolution, cooperation with KPMG’s Global Transfer Pricing Services network plays a special role. Indeed, there is no point in achieving good results for one country’s branch, when these results are achieved at the expense of a branch in another country.
In addition, we make use of our multidisciplinary tax approach. In doing so, we work closely with Meijburg & Co’s corporate income tax, customs and VAT specialists, and KPMG’s audit and IT specialists. As a result, we can provide you with integrated solutions. So you can avoid situations in which an inferior VAT or customs position negates your successful Transfer Pricing outcome.
Want to know more about Controversy and Dispute Resolution?
If you would like more information about Controversy and Dispute Resolution, Meijburg & Co would be pleased to discuss this with you. Please contact one of our Controversy and Dispute Resolution specialists.
