Eversheds: Transfer Pricing Under Pressure: Navigating an Era of Heightened Enforcement and Global Coordination

The second in a two-part webinar series featuring insights from members of Eversheds Sutherland’s premier Tax Practice on the most significant developments shaping today’s tax enforcement landscape. Part of our Developments in Tax Administration, Controversy, and Enforcement (ACE) program, these sessions will highlight where tax authorities are focusing their attention—and how taxpayers and advisors can stay ahead of emerging risks. CLE/CPE credit will be offered. 

Transfer pricing has moved from a technical compliance exercise to the single largest area of international tax controversy. Tax authorities around the world are devoting unprecedented resources to challenging intercompany pricing arrangements, armed with more data, more sophisticated analytical tools, and greater cross-border coordination than ever before. This presentation will examine the role of the global tax advisor in the current transfer pricing enforcement landscape and provide practical guidance for multinational companies navigating this increasingly complex environment.

Key topics will include:

• The evolving role of comparability analysis – how tax authorities and courts are evaluating benchmarking studies, the selection of comparable transactions, and the use of profit-level indicators.
• When and how to pursue unilateral, bilateral, and multilateral Advance Pricing Agreements to achieve certainty and reduce audit exposure.
• Navigating Mutual Agreement Procedures to eliminate double taxation.
• The impact of tariffs on transfer pricing considerations

After attending this program, participants will be able to:

• Identify key domestic and international tax enforcement trends, including recent court decisions, evolving IRS priorities and increasing global coordination among tax authorities.
• Analyze how judicial doctrines and international tax frameworks are being applied by courts and tax authorities to challenge taxpayer positions.
• Evaluate practical considerations and strategies for taxpayers and advisors in responding to audits, controversy and enforcement activity.

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Fee:

Complimentary