A change in tax policy has been an extensively discussed issue globally, and recent political and public concerns about tax avoidance have energised tax regimes globally to update laws and regulation in this regard.

In this Note, we aim to highlight some of these concepts and circumstances in which taxpayers are subject to transfer pricing and tax legal challenges. The main takeaway of the article aims to highlight learnings on common litigation issues observed in transfer pricing and tax disputes against the Tax Authority, the aspects and actions that taxpayers should be aware of and follow when litigating with the Tax Authority, and the actions to implement into their transfer pricing or tax strategies once these disputes are resolved.

• Tax Authority: The official entity responsible for the collection and administration of taxes.

• TP : Transfer pricing