At an administrative and court level, we assist taxpayers with transfer pricing audits and resolve transfer pricing disputes. Resolving international transfer pricing disputes through mutual agreement procedures (MAPs), using arbitration under tax treaties, or through the EU Arbitration Convention, Loyens & Loeff is able to work simultaneously across multiple jurisdictions. Furthermore, our transfer pricing team has extensive experience in successfully obtaining (bilateral) Advance Pricing Agreements (APAs), which helps limit complications in the event that additional disputes arise.
State Aid transfer pricing checks
State Aid has become a bigger challenge for private companies, following more intensive research by the European Commission. The European Commission has been investigating how national and local authorities facilitate fiscal state aid and so, in turn, this has become an important theme for companies. The European Commission felt compelled to address this issue, due to increasing public disquiet.
As a company, it is important to examine the risks that arise from fiscal state aid and then identify how these risks can best be controlled. Different options can then be identified and choices made, that can then be explained to the different stakeholders.
Do you require insights into the risks involved? Do you need a specialist who can highlight the risks that are relevant to your current activities and set out a range of possible scenarios, combined with the values that you might expect? We can help you with this. Insights based on thorough analysis, enable you to clearly identify which risks require action and which ones don’t. Above all, it is essential that you are in control. Only by being aware of all the risks, you can make informed choices.
Dispute resolution & Audits
International companies are dealing with a fiscal environment where tax administration is becoming increasingly important and for many of these companies, tax administration, itself, is increasingly focused on transfer pricing. The administration resulting from internal transactions is subject to periodic audits. The way in which a company operates in other countries, will determine what tax structure is appropriate and disputes can arise if there is a lack of insight and overview. Dispute resolution is centered on a pro-active approach and resolution mentality.
Loyens & Loeff specialises in issues relating to dispute resolution & audits. We can provide you with a range of options, enabling you to make informed decisions and to rethink tax structures, strategies and administrative systems, so that future disputes can then be minimised.
Disputes can arise for a number of reasons. We have created a vision and structure to assist you in moments like these. By offering a variety of options, you are able to stay in control and decide for yourself, which approach fits best to your business strategy and vision.