TP Audits – Get Your ‘Hard Hat’ at TP Minds International!

It’s TP Minds International this week, and I’m looking forward to contributing to a panel discussion on ‘Managing TP Audits and Defending Your TP Position’ on Wednesday 16th at 13.05 BST. The discussion will feature Catherine Harlow, Head of TP at AstraZeneca and Kurt Wulfekuhler, TP Director at Verizon Communications, and will be chaired by Anton Hume, International Tax and TP Partner at BDO LLP.

The panel discussion will be a great opportunity to discuss themes such as mock TP audits, ‘horizontal tax monitoring', the role of agreements in TP audits, practical approaches to managing audits when they arise, as well as MAPs and dispute resolution.

Fixing gaps and errors in intercompany agreements is of course a key part of getting ‘audit ready'. As you may know, my colleagues Leiza Bladd-Symms, Ivan Hanna and I will also be hosting a roundtable discussion on that subject at TP Minds International. The roundtable session will start at 12.20 BST tomorrow, 15th June.

We will explore key questions challenging practitioners such as:

• How can MNEs implement their TP policies legally, without creating vast amounts of lawyerish gobbledygook?
• What are the real lessons from Coca-Cola? (apart from the unintelligible arguments about economic theory)?
• Which contractual terms are tax authorities most likely to focus on in a TP audit?
• What should we do if we have large gaps in our Intercompany Agreements?
• Or if we know our agreements don’t match our TP policies?
• How can we ‘future proof’ our Intercompany Agreements?
• How should we manage agreements as part of ongoing operational transfer pricing?

If you’re planning to attend the conference, please do drop by on both sessions, and I look forward to seeing you there.