Conducting a Transfer Pricing Trial, Audit to Court Playbook
Table of Contents
Many transfer pricing teams still treat risk as an annual documentation exercise. Build the local file, update the benchmark, finalise the narrative, move on.
Here is the thing: that approach can work right up to the moment it does not.
When a transfer pricing dispute escalates, the centre of gravity shifts. The issue stops being theory and starts being evidence, behaviour, governance, and the credibility of your story under pressure. At that point, you are no longer writing for internal stakeholders. You are writing for a tax authority, and sometimes for a judge.
This is the gap that Conducting a Transfer Pricing Trial is designed to close.
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What makes transfer pricing disputes different from transfer pricing work
Most technical guidance teaches pricing and documentation. That is useful, but it does not prepare teams for what happens when a tax authority says:
- Your documentation does not match operational reality
- Your FAR analysis is inconsistent with who actually makes decisions
- Your evidence does not support risk control, capability, or accountability
- Your story changes under questioning, because it was never built on decision proof
In disputes, the tax authority is not only evaluating numbers. They are evaluating credibility.
That is why disputes are lost. Not because the method is always wrong, but because the evidence file cannot carry the story when challenged.
What the book covers: from audit pressure to cross examination
Conducting a Transfer Pricing Trial is not a compliance guide and it is not a theoretical textbook. It is a practical playbook for how transfer pricing disputes unfold in audits and courts, written from the perspective of someone who has been inside real disputes and has argued cases in court.
Inside the book, you will learn:
- How tax authorities build transfer pricing cases and where they look for leverage
- How bad evidence is created, often accidentally, through emails, minutes, approvals, and inconsistent narratives
- How to build a defence file that survives cross examination, not just peer review
- Why FAR analyses can fail under oath when decision evidence is missing
- Why documentation collapses when it is written for the wrong audience
- How to manage transfer pricing as an enterprise risk, governance, and narrative discipline
This is about trial readiness, even if you never see a courtroom, because the behaviours that win in court also win in audits and appeals.
Who the book is for
This book is written for professionals who sit where the risk becomes real:
- In house tax leaders managing audits and controversy
- Transfer pricing professionals moving beyond benchmarking and compliance cycles
- Lawyers preparing objections, appeals, and litigation strategy
- Advisors who want to reduce surprises when audits turn hostile
If you sit in front of a tax steering committee, manage cross border risk, or face heightened scrutiny driven by country by country reporting and coordinated audits, the frameworks in this book are built for your reality.
Why this approach matters now
Tax authorities are challenging transfer pricing through data, governance signals, and behavioural indicators, not only through comparables. The dispute environment has become more integrated and more sceptical, especially around intangibles, risk allocation, and decision making.
That means the winning approach is the one that aligns:
- The transaction story
- The decision record
- The operational behaviour
- The governance framework
- The evidence file
When those elements line up, the analysis becomes defensible. When they do not, even strong technical work becomes fragile.
Get the book and implement the framework
Conducting a Transfer Pricing Trial is available now.
As an added benefit, Dr Erasmus is available for a short consultation to help you set up a practical tax risk management structure to implement the insights and frameworks from the book inside your organisation.
If you want to stop treating transfer pricing as a yearly report and start managing it as an enterprise level risk, this book will change how you work.