The Rising Role of Transfer Pricing in Tax Planning and Litigation

01 December 2018
Philip de Homont

Associate Director Philp de Homont contributed the section “The Rising Role of Transfer Pricing in Tax Planning and Litigation” to the Tax 2018 Expert Guide by Corporate LiveWire. In his article, Mr. de Homont explains how increased scrutiny by tax authorities and the trend toward globalization pose challenges to transfer pricing and tax planning. He discusses trends in the focus of auditors in high-profile litigations, including the use of “DEMPE” functions for intangibles, brand licensing benefits questions, and hard-to-value intangibles. He also suggests ways in which tax departments can protect against or address these issues.