Arcotia Hatsidimitris - International Tax Dialogue

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48 – 5. MAINTAINING PROGRESS, TACKLING DELAY advisors knew what to expect from the tax administration and publication could help demonstrate consistency of approach and therefore support actions taken by the tax administration. <strong>Tax</strong> administrations, business and their advisors noted that where guidance is published it can be very helpful, both to business and the tax administration, to consult with external stakeholders whilst the guidance is still in draft so that issues or concerns can be addressed by the tax administration before the guidance is finalised, usually leading to a much better product. Deliberate obstruction Most tax administrations recognise the need to regularly reassess the scope of their audits and enquiries to ensure that they remain relevant. In a similar way they need to ensure the reasonableness of their requests, particularly where they set tight deadlines. However, sometimes despite all efforts to do this and engage with a business, tax administrations can be faced with outright opposition to their attempts to undertake an audit or enquiry. Where this happens they need to have ready strategies that can be deployed to counter such obstruction; for many tax administrations this can involve the use of information powers, the ability to estimate assessments and to close cases using legal processes. Having the ability to use all of the means of tackling delay outlined in this chapter should, however, mean that these are only strategies of last resort and seldom need to be used. Key thoughts for chapter Most tax administrations have experience of transfer pricing audits or enquiries that run for many years. Often the cause of delay lies in the fact intensive nature of transfer pricing work and disagreements over the provision of business records. Early discussion about the aspects of the business to be reviewed, carefully focused requests for records and agreed timetabling can ensure a speedy and effective outcome to audits or enquiries. The development of alternative dispute resolution techniques in several countries suggest that this approach may be of use in transfer pricing cases. DEALING EFFECTIVELY WITH THE CHALLENGES OF TRANSFER PRICING © OECD 2012
6. REACHING A DECISION POINT – 49 Chapter 6 Reaching a decision point This chapter considers the closing stages of an audit or enquiry and the process of deciding the final outcome. In particular it looks at the way in which decisions to settle or litigate are reached, the process of negotiation, the role of an internal appeals function and litigation. DEALING EFFECTIVELY WITH THE CHALLENGES OF TRANSFER PRICING © OECD 2012
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ITD Transfer Pricing Conference: Tr
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Dealing Effectively with the Challe
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5 a) Organizational set-up Challeng
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5 a) Organizational set-up Head Off
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5 a) Organizational set-up National
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5 b) Staffing, training and managin
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Transfer Pricing Learning Curve Pot
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EXAMPLE: Training of the staff - CR
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ORGANISATION FOR ECONOMIC CO-OPERAT
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