Transfer pricing (TP) is again identified as the main tax risk by multinationals in the EY 2021 Tax Risk and Controversy Survey, making it the top risk in the last four biannual surveys. A second 2019 EY survey further indicates that 80% of companies experienced challenges to their TP positions in the three years up to 2019.
It is in this context that tax leaders are increasingly focused on building a controversy department fit for the future — one in which a proactive approach to TP controversy …