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Multinational enterprises have been facing disputes with tax authorities since their very inception and these have only been increasing over the course of time, and with the implementation of the proposals suggested in the Base Erosion and Profit Shifting project a further increase in the number of disputes is predicted. This can also be attributed to the fact that BEPS is primarily aimed at combating tax evasion and not simplifying or clarifying dispute resolution framework. As BEPS will soon have impact on corporates’ intercompany transactions, they need to proactively develop a dispute avoidance and resolution mechanism that extends beyond mere compliance with various sets of regulations existing in all the countries of operation. TPA suggests multinational corporations to spend 20% time on compliance with various TP rules so that their tax professionals can focus 80% of the time on risk assessment and management. The primary aim of this booklet is to answer one essential ques
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