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

The OECD profile signals Brazil is no longer a jurisdiction where TP can be treated as a mechanical compliance exercise, one expert suggests, though another highlights “significant concerns”
Libya’s often-overlooked stamp duty can halt payments and freeze contracts, making this quiet tax a decisive hurdle for foreign investors to clear, writes Salaheddin El Busefi
Eugena Cerny shares hard-earned lessons from tax automation projects and explains how to navigate internal roadblocks and miscommunications
The Clifford Chance and Hyatt cases collectively confirm a fundamental principle of international tax law: permanent establishment is a concept based on physical and territorial presence
Australian government minister Andrew Leigh reflects on the fallout of the scandal three years on and looks ahead to regulatory changes
The US president’s threats expose how one superpower can subjugate other countries using tariffs as an economic weapon
The US president has softened his stance on tariffs over Greenland; in other news, a partner from Osborne Clarke has won a High Court appeal against the Solicitors Regulation Authority
Emmanuel Manda tells ITR about early morning boxing, working on Zambia’s only refinery, and what makes tax cool
Hany Elnaggar examines how AI is reshaping tax administration across the Gulf Cooperation Council, transforming the taxpayer experience from periodic reporting to continuous compliance
The APA resolution signals opportunities for multinationals and will pacify investor concerns, local experts told ITR
Gift this article