A foreign based multinational was requested to submit transfer pricing documentation for audit purposes.
Before submitting the documentation, it was reviewed in detail to ensure that transactions were sufficiently supported by a quality comparability analysis and factual information including allocation schedules for cost data, which turned out to be the main audit topic.
A strategy for the audit was agreed and the necessary documentation was submitted. During the audit, the strategy was revisited before major events and supplementary documentation was procured and submitted to the tax authorities.
Several meetings were held with the tax authorities, both with and upon agreement with the client without the client present during the meetings, to accommodate an effective and professional audit.
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