Transfer pricing controversies globally have in recent years caused a shift in how companies prepare for audits, which methodologies they use, and how much documentation they need.
As well as changes to auditing, court decisions in key US disputes involving Coca-Cola and Medtronic have highlighted how much certainty a company can expect from advance pricing agreements—APAs— given by the government, as well as pondering the way companies can use different transfer pricing methodologies.
Bloomberg Tax spoke with Tomoko Ikawa, partner at Law firm Simmons & Simmons in the UK, about why companies are beefing up their defense files in ...