Arcotia Hatsidimitris - International Tax Dialogue

28 – 2. SELECTING THE RIGHT CASES
Key thoughts for the chapter
The challenge for tax administrations is to maximise yield while ensuring that business and other
stakeholders have confidence in the tax system. This requires transparent processes for deciding how
tax compliance risks are to be addressed. This is particularly important in the context of transfer
pricing audits and enquiries which can be very resource intensive for tax administrations and business
alike.
Business, their advisers and tax administrations are all agreed that the benefits of effective
transfer pricing risk identification include:
• More targeted and thus more cost-effective use of limited resources from a tax
administration’s perspective;
• Clearly defined documentation requests which reduce both the demands on business in
providing the documentation and the time and other resource burdens on the tax
administration in reviewing it; and
• Shorter timescales for audits or enquiries and for resolving disputes, which are clearly
advantageous to both business and tax administration.
DEALING EFFECTIVELY WITH THE CHALLENGES OF TRANSFER PRICING © OECD 2012