Transfer pricing controversy is rarely won on theory alone. In practice, outcomes are shaped by preparation, evidence, and the ability to explain a consistent story under pressure.
In this episode of The Transfer Pricing Method, host Adriaan van der Heijden is joined by:
Together, they break down what really drives transfer pricing audits today, what “audit-ready” documentation looks like in practice, and how to manage the first steps of an audit without creating unnecessary risk.
You will learn:
Prefer reading? The blog summarising this episode is available here.
Timestamps
00:00 Introduction & Guest Backgrounds
01:17 Why TP audits start today (data visibility and inconsistencies)
03:55 Typical audit triggers (financial outcomes and documentation risk signals)
04:55 Prevention and the shift from “tell me” to “show me”
06:50 Audit readiness starts before documentation (policies, processes, controls)
09:35 Audit-ready TP documentation: approach and structure
12:41 What makes transfer pricing documentation audit-ready?
17:49 Evidence and data: can you actually prove your position?
20:10 Practical tips for audit readiness (what to do in practice)
23:30 What to do when the tax authority has a point
27:45 Summary & Closing Remarks
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