Multinational enterprises have been facing disputes with tax authorities since their very inception and these have only been increasing over the course of time, and with the implementation of the proposals suggested in the Base Erosion and Profit Shifting project a further increase in the number of disputes is predicted. This can also be attributed to the fact that BEPS is primarily aimed at combating tax evasion and not simplifying or clarifying dispute resolution framework. As BEPS will soon have impact on corporates’ intercompany transactions, they need to proactively develop a dispute avoidance and resolution mechanism that extends beyond mere compliance with various sets of regulations existing in all the countries of operation. TPA suggests multinational corporations to spend 20% time on compliance with various TP rules so that their tax professionals can focus 80% of the time on risk assessment and management. The primary aim of this booklet is to answer one essential question: ‘how should businesses be addressing the increased level of disputes?’, especially in light of abundant regulations adopted by numerous countries as an aftermath of BEPS. Through this book TPA Global offers clear and concise guidance to multinational enterprises to be “in control” of their organisation’s operations and to be adequately prepared to avoid disputes and/or successfully battle them. It contains an overview of all the possible dispute avoidance and resolution tools accessible by corporates and the availability of such tools per country.
