Transfer pricing controversy and dispute resolution

Governments around the world are focused on transfer pricing enforcement. This situation places a premium on audit and dispute prevention techniques because multinational companies (MNCs) are under constant competitive pressure to structure their worldwide business operations effectively and efficiently.

MNCs need to develop coordinated approaches to audits and disputes around the globe, adopt preventative measures (such as pre-filing rulings and enhanced relationships with certain revenue authorities), and leverage effective dispute resolution techniques in order to achieve the best possible results.

We offer a comprehensive suite of transfer pricing controversy services, underpinned by collaborative technologies and global expertise. Our capabilities span the full dispute lifecycle—from early risk identification and audit preparedness to strategic resolution of complex cross-border controversies, e.g. Mutual Agreement Procedure (MAP). We are committed to keeping your organisation resolution-ready, delivering trusted outcomes through proactive risk management and tailored dispute strategies.

APA

As tax controversies increase globally, companies are facing even more challenges to mitigate tax risk and achieve tax certainty. APA remains an effective tool for achieving those goals.

In China, an APA is a method of reducing the likelihood of an audit, reducing compliance costs over the term of the APA and to provide certainty around a company's tax outcome regarding their international transactions.

How we have helped?

• Assistance in transfer pricing audit cases across Mainland China and Hong Kong in all industries, including automotive, electronic components, office equipment, heavy equipment, franchising, retail and consumer etc.
• Played a vital role in China's first Mutual Agreement Procedure case, granting relief for the affected taxpayers.
• Represented our clients to conclude the first five formal APA cases in China.
• Assisted in the majority of bilateral advance pricing arrangements (BAPAs) concluded in China, including the first BAPA with Korea, Singapore and Denmark.
• Advised on the first China outbound APA.