Managing Tax Disputes Summit: Mismatches in global TP audits laid bare

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Managing Tax Disputes Summit: Mismatches in global TP audits laid bare

Taxdisputes_panel.jpg
L to R: Derya Bresser; Carolina del Campo; Brad Rolph

Speakers at ITR’s Managing Tax Disputes Summit said taxpayers can still face lengthy TP audits, despite strong documentation preparation

Taxpayers may have strong transfer pricing documentation in place but authorities’ aggressiveness could still lead to lengthy audits, according to experts at ITR’s Managing Tax Disputes Forum yesterday, September 27, in Amsterdam.

In Spain, for example, taxpayers can expect a TP audit to last for 27 months on average.

“It’s common, especially in TP, that they [tax authorities] open for three years and close for adjustment,” explained Carolina del Campo, partner in TP and tax governance at law firm Cuatrecasas based in Madrid, during the panel.

“If you don’t do it, they would normally open a new tax audit,” she added.

Spanish law demands taxpayers to prepare TP documentation including the master and local file, while larger groups must also follow country-by-country reporting requirements.

TP adjustments arising from audits are common, meaning preparing ahead of that adjustment before tax authorities make any investigation is even more crucial.

Most importantly, TP audits in Spain are not only targeted at multinationals but also at smaller firms with domestic transactions.

“They [tax authorities] are making an exchange of information for TP matters, such as asking about the TP policy and are incorporating that information in the audit,” said del Campo.

“From the beginning, you need to find a strategy. Try to look at tools available,” she added.

Going after ‘everyone’

Brad Rolph, partner and national leader of TP at consulting firm Grant Thornton in Canada, stressed the Canada Revenue Agency’s (CRA) aggressiveness towards corporations’ TP documentation.

“Canada goes after everyone,” said Rolph.

The CRA’s request for TP adjustments depends on each particular case and individual transaction, according to Rolph.

TP audits in Canada will most likely require a company’s TP documentation based on a query sheet.

“They have a standard form and would ask you a standard form of question. Some auditors like to find the information required – they will try to do a field audit as much as they possibly can,” explained Rolph.

However, the Canadian TP laws also lack specific regulations, according to Rolph. While the CRA recognises OECD guidelines, the laws do not incorporate the guidance itself.

Since OECD reports are not formally recognised by the Canadian courts, corporations are solely required to keep all records of non-arm’s-length transactions.

“It’s the law that matters and not the OECD guidelines,” said Rolph.

But tax authorities’ level of aggressiveness also depends on their resources, according to Rolph.

As opposed to the CRA, the Internal Revenue Service lacks resources to go after smaller firms when it comes to TP audits, meaning companies within this scope are less likely to be targeted by the US tax authority.

The US has strong TP laws in place, requiring taxpayers to maintain a range of information known as the principal and background documents. This can include anything from a description of the company’s organisational structure to an explanation of comparables used.

ITR’s Global Transfer Pricing Forum Europe is also taking place in Amsterdam, on September 28 and 29, and we will be bringing you more coverage from that event.

more across site & shared bottom lb ros

More from across our site

Meanwhile, one expert highlights the importance of separating Venezuela’s tax authority from direct political control after ‘lost decades and isolation’
With PMK 108, Indonesia has upgraded its tax transparency regime for the digital era, focusing on data quality, governance, and cross border exchange rather than expanding regulatory reach
In a popular LinkedIn post, Jeremie Beitel encouraged firms to invest in junior talent even if it doesn’t lead to their loyalty, though recruiters offered ITR a mixed assessment
Advisers who do not register for the new regime in time could be prevented from interacting with HMRC, the tax authority said
Valid pillar two objectives are still intact after the side-by-side agreement, but whether the framework is now settled is ‘a $64,000 question’, Morrison Foerster’s tax chair told ITR
Ian Halligan previously led Baker Tilly’s international tax services in the US
Exclusive ITR data emphasises that DEI does not affect in-house buying decisions – and it’s nothing to do with the US president
The firms made senior hires in Los Angeles and Cleveland respectively; in other news, South Korea reported an 11% rise in tax income, fuelled by a corporation tax boom
The ‘deeply flawed’ report is attempting to derail UN tax convention debates, the Tax Justice Network’s CEO said
Salim Rahim, a TP specialist, had been a partner at Baker McKenzie since 2010
Gift this article