One of the things I love about attending conferences like TP Minds International last week is that (as an adviser) you get insights into the real-life practicalities of managing TP risks, as opposed to just high-level theory and crystal ball-gazing.  

One of the polling questions we asked on the panel session I hosted on TP audits was ‘Do you have a protocol for handling TP audits?’

Interestingly, around 42% of respondents said ‘No’.

The scenario we’re talking about here is very simple. One of your local subsidiaries – maybe in a far-flung country – receives a TP related enquiry (or is even subject to a dawn raid from the ‘tax police’).

Who should the local representatives contact internally about this?

Which local or international advisers should they call?

What approach should the local team adopt generally, when dealing with the tax inspectors?

Where are the TP files kept?

Where are the intercompany agreements kept?

If you have a written protocol for handling TP audits, please drop us a quick email at and let us know what other items your protocol covers. We’ll be very happy to produce a consolidated checklist (anonymized, of course), and share it so that it is available to others for free.