STI Taxand has expertise in resolving various conflicts and in applying a sound and creative economic theory for resolving tax disputes.

Advance Pricing Agreements in Cyprus (APAs) and Competent Authority Negotiations

STI Taxand team consists of experts that have the necessary skills and knowledge to structure the economic framework of advance pricing agreements in Cyprus (APAs) and assist competent authority (CA) negotiations between tax authorities. While key negotiation issues may vary among cases, STI Taxand provides a wide range of support services, such as:

• Negotiating with tax authorities taking into account tax authorities’ position and potential points of conflicts;
• Supporting the taxpayer’s position with sound economic analysis and evidence and detailing to the tax authorities the underlying economic theories and business practices;
• Facilitating discussion and resolving “standoffs” to negotiations by developing alternative methodologies.

Tax enquiries and disputes have a negative impact on your firm’s reputation. They are timely, resource intensive and can lead to higher taxation rates. Our dispute resolution service team provides help in resolving various questions about transfer pricing Cyprus when dealing with tax authorities.

Transfer Pricing Audit and Litigation Support

STI Taxand experts have substantial experience in assisting clients who are undergoing transfer pricing audits in many countries. Our experts have worked extensively and successfully with taxpayers and their lawyers to address needs arising in a variety of audit support cases. We can provide assistance in the following ways:

• Conduct objective and fact-based analysis in the early stages of the audit to assess the strength of a tax authority case, and develop an overall negotiation strategy based on that assessment;
• Assess the requests made by tax authorities and prepare the appropriate responses, explaining the reasons for the analysis;
• Analyze and assess any adjustments proposed by the tax authorities.