The operating model goes to the heart of the tax profile of any group and can be a significant driver of their effective tax rate. If choosing an area of focus to uncover high-risk transfer pricing issues, it would be on the multinational’s operating model and how the transfer pricing policies being applied in practice align with this. If not, they can build up significantly over time, leading to material tax exposures at the time of completing the deal. It is prudent to see that these risks are managed appropriately by involving transfer pricing specialists as and when they arise and well in advance of the deal.
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