As governments and tax authorities are increasing their focus on transfer pricing issues, aggressive audit approaches and appeal techniques, multinationals should also ensure their integration with internal and external counsel is aligned. This alignment should be in place prior to having to submit a reactionary response that is time constrained, complex and material in amount. The following considerations are provided to promote discussion of this important topic among your teams and senior management.
- What is the reporting structure for tax and legal?
- Are dedicated tax counsel on the tax and/or legal team?
- Does tax meet quarterly with internal/external counsel for status updates?
- Have you quantified the benefit for justification of full-time internal tax counsel?
- Where should internal tax counsel be located, contrasted with the tax team structure?
- Should tax counsel have a full-time presence in aggressive jurisdictions for which appeals and trials are significant?
- Who interviews tax counsel candidates?
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