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Transfer Pricing Dispute Resolution

Defending your transfer pricing policy

Transfer Pricing Dispute Resolution

KPMG LLP’s (KPMG) Transfer Pricing Dispute Resolution (TPDR) Services team can help you resolve disputes and respond to challenges that come with transfer pricing controversy—domestically or globally.

Dive into our thinking: ​

Advance pricing agreements - The why and the how of here and now

Read about the historical and current motivation to pursue an APA and how to negotiate an APA

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Evolution and Future of the MAP

KPMG shares view on the mutual agreement procedure process and its future

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About Our Services
  • About Our Services
    +4 services
  • 01
    Transfer Pricing Dispute Resolution - Overview
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  • 02
    Defend your transfer price - The right team to help you
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  • 03
    Advance pricing agreements - The why and the how of here and now
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  • 04
    US-Japan Advance Pricing Agreements
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Articles and Insights
  • Articles and Insights
    +13 services
  • 01
    Taxing the Digital Economy—As Simple as ‘A, B, C’?
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  • 02
    8 Common Challenges To Trademark Royalty Deductions
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  • 03
    CAP Updates Bring Transfer Pricing Issues to the Fore
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  • 04
    The Alphabet Soup of Value—Making Sense of IRS’s New Transfer Pricing Model
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  • 05
    FCD Model: A New Tool for APA Submissions
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  • 06
    New Directive Formally Acknowledges Adoption of IRS Wide Position on Multiple RAB Shares in CSAs
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  • 07
    The Problem With Prediction In Transfer Pricing
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  • 08
    IRS Instructs Exam Teams to Hold Transfer Pricing Documentation to a Higher Standard
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  • 09
    Outlook for U.S. Advance Pricing Agreements
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  • 010
    International Compliance Assurance Programme—Oasis or Mirage?
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  • 011
    BEAT Impact on Transfer Pricing Alternative Dispute Resolution
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  • 012
    The IRS and the APA: Denial Is Not a Strategy
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  • 013
    U.S. APA Program Changes Positively Impact U.S.-Japan APAs
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Advance Pricing Arrangement Series
  • Advance Pricing Arrangement Series
    +4 services
  • 01
    Advance Pricing Arrangement Series: Asia Pacific (May 5, 2020)
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  • 02
    Advance Pricing Arrangement Series: Europe (September 3, 2019)
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  • 03
    Advance Pricing Arrangement Series: Americas (June 24, 2019)
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  • 04
    Advance Pricing Arrangement Series: China (June 10, 2019)
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Tax Dispute Resolution
  • Tax Dispute Resolution
    +2 services
  • 01
    Tax Dispute Resolution Quarterly
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  • 02
    Tax Dispute Resolution Services
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Post-BEPS Controversy Readiness
  • Post-BEPS Controversy Readiness
    +3 services
  • 01
    KPMG's Tax Controversy Trackers
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  • 02
    Post-BEPS Controvery Readiness - Overview
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  • 03
    BEPS Controversy Readiness - e-Brainstorming survey results
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Explore more insights

New Horizons for Dispute Resolutions Under Pillar One's Amount A

New Horizons for Dispute Resolutions Under Pillar One's Amount A

KPMG Mark Martin and Thomas Bettge explain the benefits for multinationals of the early certainty process in the OECD report on the pillar one blueprint. Among the blueprint’s proposals is a process for the prevention and resolution of disputes regarding Amount A, which allocates taxing rights on a portion of in-scope companies’ profits to market jurisdictions.

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A U.S. Perspective on Transfer Pricing and EU State Aid

A U.S. Perspective on Transfer Pricing and EU State Aid

The authors offer views on the role of th arm's-length principle in EU state aid enforcement.

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Download A U.S. Perspective on Transfer Pricing and EU State Aid
The State of Country-by-Country Reporting

The State of Country-by-Country Reporting

In this article, the authors highlight the movement toward increased transparency and how that translates into additional compliance burdens, concluding that country-by-country reporting is here to stay.

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Download The State of Country-by-Country Reporting
A New Era for Secondary Transfer Pricing Adjustments?

A New Era for Secondary Transfer Pricing Adjustments?

In this article, the authors examine the mechanisms for and the tax consequences of secondary adjustments and analyze how taxpayers should conform their accounts following transfer pricing adjustments.

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COVID-19 and Dislocated Employees: DEMPE and Risk Control Considerations

COVID-19 and Dislocated Employees: DEMPE and Risk Control Considerations

The authors address the transfer pricing implications of employees working outside their normal business jurisdictions during the COVID-19 pandemic.

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TNF 06-22-2020.book

TNF 06-22-2020.book

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Download TNF 06-22-2020.book
IRS Issues APA Statistics for 2019

IRS Issues APA Statistics for 2019

The authors discuss the most recent U.S. APA statistics in the context of broader trends.

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Download IRS Issues APA Statistics for 2019
TNF 05-25-2020.book

TNF 05-25-2020.book

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Download TNF 05-25-2020.book
Mail - McManus, Erin - Outlook

Mail - McManus, Erin - Outlook

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Download Mail - McManus, Erin - Outlook
TNI 03-30-2020.book

TNI 03-30-2020.book

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Download TNI 03-30-2020.book
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Meet our team

Image of Thomas Herr
Thomas Herr
Principal, Tax - National Leader Transfer Pricing Services, KPMG US
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Image of Mark Horowitz
Mark Horowitz
Principal, Tax, KPMG US
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Image of Thomas Herr
Thomas Herr
Principal, Tax - National Leader Transfer Pricing Services, KPMG US
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Image of Mark Horowitz
Mark Horowitz
Principal, Tax, KPMG US
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Some or all of the services described herein may not be permissible for KPMG audit clients and their affiliates or related entities.

The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act upon such information without appropriate professional advice after a thorough examination of the particular situation. KPMG LLP does not provide legal services.

The information contained herein is not intended to be “written advice concerning one or more Federal tax matters” subject to the requirements of section 10.37(a)(2) of Treasury Department Circular 230.

© 2024 KPMG LLP, a Delaware limited liability partnership and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.

For more detail about the structure of the KPMG global organization please visit https://home.kpmg/governance.

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