4. Dispute Prevention and Resolution
We support businesses in managing transfer pricing disputes through a practical and informed approach. Our aim is to minimise the risk of disputes by ensuring your policies and documentation are well-prepared and defensible. Where issues do arise, we assist with responding to Revenue queries, navigating audits, and pursuing appropriate resolution through mechanisms such as MAPs or correlative relief.
Our focus is on resolving matters efficiently, with minimal disruption to your business and the services include:
• TP Audit Support: Providing assistance during compliance reviews and TP audits, including reviewing or responding to information requests and assistance with Revenue correspondence. • Advance Pricing Agreements (APAs): Facilitating unilateral, bilateral, or multilateral APAs to gain certainty on transfer pricing methods. • Mutual Agreement Procedures (MAPs): Navigating MAPs to resolve disputes and eliminate double taxation. • Correlative relief claim: Supporting with preparing and submitting correlative relief claims where a transfer pricing adjustment has been made by a foreign tax authority, ensuring appropriate relief is secured in Ireland under applicable double tax treaties and avoiding economic double taxation.
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