TP audits: how to avoid the red flags that trigger scrutiny

[Music] Hello and thanks for joining this ITR Transfer Pricing Podcast in collaboration with CMS. I'm Phil Meyers, the commercial editor of ITR and in this session we're going to be discussing all of its valuations, supply chains, roll of tech including AI and several other areas that we hope will be relevant to your day-to-day practice. Helping me unpick all those topics of three experts speakers from CMS. So, going around the table, as it were, given the window in the same room, we'll start with some introductions before we get into the good stuff. Firstly, Vitorios Segre. Good morning and thank you for inviting me to this post-cast. I am a tax partner at the International Law and Tax firms CMS, based in Rome and have over 10 years' experience in transfer pricing. Thank you. And moving on to Mohammed Hajj Taib. Thank you very much. So, very pleased to be with you this morning. I am Mohammed Hajj Taib. I am tax partner with the CMS Francis Lefab. I am working on TPP for 20 years. Okay, thank you. And finally, have fun trying a risk. Hi everyone. Thanks for having me too. So, my name is Andrea and I'm a senior associate at CMS Francis Lefab. I've been working there since 2019 now, specializing in international tax law and more particularly in transfer pricing. That's great excellent. So, I'd like to start with Vitoria, if I may, and ask you to share what trends you're observing in the treatment of insurance companies services recently. Yeah, let's start from facts. According to 2023 report published by the tax police, the most frequent challenges in international tax in Italy are permanent establishments, tax residents, as well as transfer pricing. And compared to the past, when audits on transfer pricing were occasionally performed by the tax authorities, the focus has grown enormously. Nowadays, it is not only large multinational groups that know how to deal with transfer pricing issues, even small or medium sized groups with limited presence abroad have included transfer pricing in their risk management strategies. The audits both focus on classic and new challenges. Classic trends are those that probably occur in other jurisdictions as well, for instance, tax authorities may highlight discrepancies between the business profile of an Italian entity and its remuneration or between group level prices and prices charged to third parties. Alternatively, a tax audits may focus on simpler issues such as whether the comparables that were picked for the benchmark analysis are relevant, operate in the same industry, perform the same functions or whether they are independent companies. The audits will also establish whether sufficient information on comparables is available. Interesting. So the audits are really digging into both the big picture and the details. Are there any other areas of heightened focus recently? In terms of new trends, particular attention has been paid to financial transactions, especially cash pooling and loans. Typically, the tax authorities address conduct inconsistent with the key features of the chosen financial instrument. Alternatively, they may simply conclude that the interest rate is not at arms lend. Another approach is to compare the previous interest rate with the new one adopted when no grounds for the change has been identified. Lastly, tax authorities frequently challenge M&A transactions in order to assess their potential tax implications starting from exit tax, configuration of a permanent slap wish and changes in the functional profile impacting transfer pricing policies. So if a company transfer functions assets or risks to another related entity, including for instance, customer lists or IPs or if a bilateral agreement is terminated or renegotiated, this could have an impact on profitability of the entity losing those capabilities. And from an Italian perspective, this could be perceived as a loss of profit potential that justify and audit. Okay, thank you. Mohammedan and Draya, lots to bring you in here. Is that the picture that Victoria Payne's consistent with what you've seen in your practice some in terms of audits? They've been evolving recently? Yeah, thank you, I confirm, because transfer pricing audits are increasingly line with international trends. So we are observing the same kind of tax audits focusing primarily on financial transactions as indicated earlier by Victoria, especially intercompany interest rates. In addition, we have also a lot of tax audits focusing on the intangible assets and the manner that intangibles are reminirated within international groups. So the value allocation of the remineration of intangibles are an area of focusing here in France. And lastly, we have a specific subject in France, which are management packages. So there is a lot of volatility in France regarding management package. What we observe also, Franchetax administration has adopted the new amendments that were introduced in 2022 by OECD in its transfer pricing guidelines. So after some hesitation, Franchetax administration, not only but also the courts, have managed to establish a framework for intangible assets, as well as financial transactions, especially interest rates between associated companies. So these topics continue to attract the attention of Franchetax inspectors. They actually require a lot of precautions and sometimes even corroborative analysis. Another key topic is management fees. So again, we have a new legislation in France because we have a new applicable regime which was enacted by the finance law in last February. Management fees remains very complex and an STD issue that requires a high level of technical expertise. So the last three four notably affect the taxation of gains from management packages that include stock option and free shares. And interesting overview there, Andrea, or anything to add on that? Yes, just to add something, I'm confirming what Victoria said that in France also, Trans-Surprising Audits have become increasingly systematic. In most cases, today, not dates of a multinational enterprise includes a particular nod of its Trans-Surprising policy. And the reassessments in the field of Trans-Surprising are often significant. For example, in 2023, you can count 2.3 billion euros reassessments. Also, for the tax audits, there are more and more documentation focused because Trans-Surprising documentation used to be requested only in selected cases, but now it is regularly requested by the tax authorities as part of the tax audit procedure. So the documentation was requested by the FDA in 470 procedures in 2023 for example, compared with 449 in 2022. So you can also notice that at the start of the audit, the documentation was asked in 78% of cases at the same period. So the tax audit procedures are more and more documentation focused. And also with the inference threshold for triggering the documentation, which was lowered by the Finance Act for 2024. This is also pushing more and more documentation oriented tax audits. Also, the French Finance Act for 2024 provides that its content becomes enforceable against the taxpayer. So where the taxpayer's transfer pricing method deviates from the one set out in the documentation, the difference is deemed to constitute an indirect transfer of profits. So now it is up to the taxpayer to demonstrate that no transfer has taken place. So this is a big change also since the Finance Act for 2024. Okay, thank you. So we're getting a good idea of some of the red flags that trigger to appeal audits. So clearly the next question is how can they be avoided? How can tax authority scrutiny be avoided? Again, I'd like to go around the table on this one and come back to Victoria first. Well, in Italy, the main red flag is the absence of TIP documentation as declared in the tax return. The TIP documentation in Italy is not mandatory, but if prepared, within the required timeframe, and if it is complete and compliant with the TIP guidelines, it allows the taxpayer to benefit from protection against administrative and criminal penalties. So from an Italian perspective, it is strongly recommended to have a robust TIP documentation. Also very interesting in Italy, the TIP documentation must be digitally signed and timestamped before the deadline and cannot be amended afterwards, which is a difference with other jurisdictions. For the taxpayers who have prepared TIP documentation in accordance with the Italian requirements, audits normally begin with a request for this documentation together with other documents. It is together with the preparation of the TIP documentation. It is also good practice to support intercompany transactions with intercompany agreements, especially if the transfer pricing policies applied by the group allow for ear end adjustments. Okay, that sounds quite strict compared to other jurisdictions. Any further considerations there? Another topic to consider is the economic analysis. An economic analysis of the arm's length nature of intergroup transactions should be performed annually based on the Italian TIP guidelines. Updates of the financials are not considered compliant with the Italian TIP guidelines, unless the group qualifies as small or medium. For example, for local file 2024, which are currently being prepared, the local file should include a new benchmark analysis based on 2021 to 2023 figures. This is usually an issue because clients do not anticipate it. It creates discrepancies with foreign entities and other jurisdictions, and of course, it includes additional costs because a brand new benchmark should be prepared, specifically for Italy. Last topic that I would like to mention is that the difference between an average low TIP documentation and a solid TIP documentation is in a detailed and robust segmented P&L. If needed, of course, to demonstrate the margins reached by a certain intercompany transaction. This is an area where groups are normally a bit fast and not particularly solid. Okay. Something to look out for there. Now, as you mentioned, documentation earlier, presumably you deck out a lot of victorious points there and anything to add? Yeah, confirm. Tax payers with the assistance of low officers, tax lawyer should prepare a minutious transfer pricing documentation that complies with tax authorities' expectation wherever the group is located. And more attention should be also granted to the preparation as a Victoria indicated of a robust benchmark analysis that allow to confirm that the transaction are reminorated, conform to the arm's length principle. So we should be very careful and very attentive to the way that our clients should prepare their transfer pricing documentation and also attention to the manner that economic analysis should be prepared. Okay. Thank you. Yes. I think we'll be coming back to you shortly on in terms of the valuation in terms of intangibles. Andrei, or anything to add there for firms, multinational as they attempt to avoid scrutiny. So I agree with my colleagues here also that maintaining robust and controversial linear documentation is really the best way to defend your transfer pricing policy. And this also comes along with a good description of the functional analysis of the company in the documentation. And also making sure that what is presented in the different elements that the company discloses, for example, statutory accounts, tax returns, other like contributed by contributing are also consistent with what is said in the transfer pricing documentation and what the company does. I mean, in sharing an alignment between transfer pricing and all the types of disclosures the company has to do is also essential in order to avoid any in order to be more vigilant. Actually. Thank you. And before we get on to valuations, I just want to ask Victoria quickly as in terms of joint audit programs such as that between Germany and Italy, do you see an increase in the adoption of those at all? Actually, experience shows that joint audits are in fact not very frequent and therefore prospectively they can only increase. Also recently, tax reform in Italy introduced new measures to facilitate the use of joint tax audits. We will see if this would be the case in the next few years. Concerning the experience between Italy and Germany based on information published by the Italian revenue agency, the cooperation between Italy and Bavaria actually have started a long time ago back in 2012. And this is a pilot project with the aim of jointly conducting tax controls on cross-border transactions between companies operating in the two states. It seems that the project provided encouraging results and the two tax administrations found a share position by jointly examining tax payers. And of course in the process they avoided the burden of the double taxation. There are other countries that have shown interest in this project and are moving forward with the first steps toward motilar cooperation. In general, since one of the main goals is to decrease international disputes, reducing the number of mutual agreement procedures and making the audit process more effective. In my view, it would be beneficial for if the joint audits will become frequent, if not on a regular basis. However, unfortunately there is no guarantee that double taxation will be avoided in the end. And many questions remain answered, particularly with respect to more difficult cases or differences in domestic laws and potentially in the future. equates staffing resources if the number of the joint audits increases in future years. Okay, thank you. It's interesting to get you the personal perspective on that. So yes, just going back to valuations moving on from audits a little, you mentioned intangibles earlier in a habit. What are some of the some of the biggest valuation challenges facing multinationals today, particularly with regards to pricing digital assets and intangibles? Yeah, the topic of valuing digital assets and intangible is actually one of the most complex areas in in transfer pricing today, especially under the new framework put in place by OECD I mean them P for development, E for enhancement, M for maintenance, P for protection and E for exploitation. So, one of the biggest challenges is that there is a difference between the legal ownership and the economic ownership. So, if you are the legal ownership of an intangible, this doesn't mean that you should be entitled with a large part of the value creation. It doesn't guarantee the right to be a full economic return. So, instead OECD guidelines require that profit should be allocated based on the actual actions or performance of DMP functions. So, if you do DMP functions, you should be well-reminorated. If you don't perform any DMP functions, your remuneration will be not much higher. So, this creates several valuation difficulties for multinational enterprises. So, in many cases you could have different entities within the group that contribute largely to the value of an intangible. For example, R&D, marketing, legal protection, distribution or commercialization actions. And if you are only a company which holds only the legal title, desperately, you cannot expect to have an important remuneration. So, now you should accurately identify which entities within the group contribute much or and largely to the value creation of intangible. So, this is the first point. Legal ownership versus economic ownership and economic ownership. That means performing DMP function. The second point to be shared with you is risk allocation and control. So, typical guidelines make clear distinction and difference between bearing and controlling the risks. So, if you are simply a funding company, you don't control the development risks and you should only expect to have a risk adjusted return, not a big share, of the residual profit. So, it requires to understand clearly which entity actually controls and manages the risk. So, if you only indicate that you are the company that bears the lots of risks but you don't do anything by controlling the risks, desperately you cannot expect to have a greater return. There is also a specific point regarding digital and marketing intangibles. It is too difficult to value this kind of assets because they are often not protected. There is not legal protection of this kind of asset and the second difficulty is the lack of market comparable. So, as it was recently indicated by the Ferryg Amou case law in France and this is a good example because the judge recognized that the French subsidiary performing marketing functions and doing a lot of efforts to enhance the Ferryg Amou brand. Even though it does not own the IP, it should be considered as an economic owner of the brand and thus should be reminirated for the marketing actions it performs. Thank you. Mohammed, while you are on a roll, I have got another question about TP functions and how they coordinate with other departments. Is it fair to say that it is becoming increasingly important for them to coordinate with other departments such as HR and legal? Thank you. This is a good question because transfer pricing is a transfer question and issue and we could not consider transfer pricing as a silhouette tax or finance issue. It is considered today as a strategic function and should be coordinated across all the departments within a group and especially as I will present with HR and legal departments. Under the BEPS-based erosion and profit shifting framework to accurately assess the multinational value creation, you should consider three elements what we could call the tryptick, the assets first one, risks second one and the third one functions. So we should analyze assets risk and functions and this is very important because it requires what we call a holistic view of the multinational enterprise. This approach should be coordinated with departments like HR and legal. From an HR standpoint, the employee location, the payroll allocation and the organizational roles are very important in the functional analysis because functions are performed by people and the most important functions should be accurately reminorated. So if we have functions, we have profits. There is a close relationship between functions and allocation of profits. We spoke earlier about the DMP functions so it is very important to defend DMP analysis and to identify eventually potential permanent establishment. So the role of HR department is very crucial. For a legal perspective or from a legal standpoint, enter company agreement, should reflect the actual conduct of the business within the group. So legal teams have to play a key role in documenting IP ownership in managing contractual risks and in defining the responsibility or and each of which affects T.P. results and the manner the risks are shared and the assets owned should affect our transfer pricing policy. So today in an environment that is becoming more and more complex in an environment where we have to manage global tax position, we should have a close relation between HR and legal teams in order to ensure a quiet speed of profits within the group. Okay, thank you. So that's the people's side importance of working together between departments. In terms of how to achieve that, is there a tech angle here and what benefits are, if any, can be derived from my documentation and risk assessment tools, other developments perhaps Vitoria could we hear from you again on this one? Yes, well in terms of audit methodology the use of AI by the tax authorities could be a real change because where traditional tax audits rely on generally three types of controls, automatic formal and merit-based, the use of AI aims to go further cross-referencing data with external resources or identifying patterns rather than near miscalculations. They also that AI also analyzes large volumes of tax payers data, identifying specific risk areas within an audit and even suggesting lines of inquiry. So this should be and is still allowing for more focused efficient audits with a higher probability of success. AI could also make a difference in terms of being prepared to audits in terms of, for instance, preparation or the TPP documentation and in performing the benchmark analysis. Gen AI enhancements introduced several AI power benefits including the ability to provide users with suggested comparables or comparison that also greater flexibility in manual reviews. So looking ahead, the rule of AI in transfer pricing is I think only set to expand and as technology evolves. However, businesses should take a balanced approach because AI could be a leverage for automation but maintaining human oversight is necessary for complex decisions and remains crucial in interpreting results and navigating complexities and of course making strategic decisions. Okay, thank you. That's really interesting to hear what you think it's going. So just moving on to advanced pricing agreements. I'm interested in getting your views on if they always provide certainty and looking at the pros and cons for M&Es. Victoria, perhaps I could stay with you on that one first. Yes, so comparing APAs with maps, we can briefly conclude that where a map resolution does not usually set a precedent or bind relevant tax administrations outside the years under review, APAs offer opportunities for future legal certainty. Also, in many countries, APAs can be applied also retroactively whereby the tax administrations can adjust the outcome of the APA to prior periods or the taxpayer can also do so. The main benefit is legal certainty which is complete in case of a bilateral or multilateral APA and limited in the case of a unilateral APA. What could be improved? In my view, the average time taken to close an APA in Italy is 42 months, so more or less 3.5 years, which is undoubtedly an issue. The tax administrations are overwhelmed by the growing number of APA requests and they, not only but some of them struggle to allocate sufficient resources to meet demand. And it is also important to be aware that for M&Es operating in the Italian market, the APA procedure does not prevent the tax authorities from performing a tax audit while the APA is ongoing. And the APA itself could potentially trigger exposure for previous fiscal years. In conclusion, there is room for improvement and an opportunity can arise alongside the APA through the OACDI Cup and the European ETACA. So these are programs that could ultimately prevent unnecessary disputes despite the fact that they are being in the early stages. So the hope is that this kind of programs will become faster, more accessible and more effective in the future. Thank you. Mohammed, is that something you recognize? The authority is being overwhelmed by APA's? Yeah, thank you. The objective of APA is to provide certainty to taxpayers. So they are conceived to the multinational enterprise to agree in advance with tax authorities on the transfer pricing methodology for some, let's say, a specific or complex transactions. So the objective behind the implementation of these agreements is to reduce the uncertainty and the risk of future audits and adjustments. So it helps to avoid double taxation. So in my point of view, APA are very useful for complex or high-value transactions where the risk of disputes is very high. However, in practice and based on my experience, certainty and guarantee is not always absolute. So we have to be aware that an important nuance is the transmission and the communication of strategic or sensitive information to tax authorities during the course of APA. So we have to be sure that the information remains compartmentalized within the APA unit. And our clients are usually asking the question what is the reality? Is the APA unit keeping the information only at their level or will they share this information with other departments within tax administration and notably the control department? So that can raise some doubts concerns for some multinational enterprise, especially when the APA involves a strategic or commercially sensitive information. sensitive information. This is the first point. The second one, we should be aware that this is a resource-intensive process, the APA. It consumes time, energy resources, and it lasts on a long period. It requires many years of discussions and negotiation and documentation. So, there is a risk during this time of negotiation of discussion. The business model of the group could evolve. It could change during the term of the agreement. So, there is no guarantee of acceptance. This is the risk when you enter into an APA discussion. There is no guarantee that at the end, the group would get an acceptance. So, but we think that it is a good strategy to reduce the risk and we appeal the clients to go into an APA process just to remind that there are three kinds of APA. The unilateral one, the bilateral one, and the multilateral one. And notably, the last one, the multilateral is the more complex because it involves many tax administrations. So, the process is very long. There is no certainty to have the agreement at the end. So, this is, we think that this is the aspect of the process that could push some clients not to enter in an APA agreement. In France, specifically, the program is well-established and it is more and more used by the groups. And especially the bilateral APA is interesting for many of our clients, but groups should carefully analyze and waive the benefits of certainty against the type, the strategic implication, the information that they would communicate to tax administration. Just one statistics in France, we count 54 of agreements by the end of 2023. And roughly, the time of negotiation is about 46 months. Okay, so it's quite close to the figure that Vittoria gave and 42, I believe it was interesting. So strong, notive caution there and there's good summary of considerations. So, I'd like to bring back Andrea at this point because she's not hurt me for a while, but also mentioned BEPS earlier. This is a really big question. Is amount B2 complex to be implemented effectively? That's a pillar one, especially when certain jurisdictions have adapted it while others have not. And try what we all thought there. So, concretely, the aim of MLB is to provide a unified and simplified approach for both tax authorities and taxpayers for baseline distribution transactions. Actually, amount B gives basic distributors of physical goods, a set profit margin. And this is worked out through a simple three step test. So, amount B is supposed to help limit the number of TPD-puts, reduce compliance costs and obligations and enhance tax certainty for taxpayers and tax administrations. Actually, the technical application of MLB is relatively simple straightforward given that the OECD provided the standardized and simplified pricing metrics that allows you to perform the computation really easily to get the target to a profit margin. However, it's true that because of the lack of consensus on amount B, there is still complexity that remains. In fact, the simplified approach non-binding nature in multiple agreement procedure cases will potentially lead to increased double taxation and diminish the simplification benefits of MLB. Disputes between countries could take place in the case a jurisdiction wants to apply MLB and the jurisdiction of the counterparty does not. And considering that the simplified approach outcomes are not recognized in mutual agreement procedure cases, tax payers in jurisdictions adopting MLB might also need to conduct a transfer pricing analysis to prepare for potential disputes. In that case, businesses may find themselves conducting two analysis, one in accordance with amount B for transactions in the distributors' jurisdiction and another based on the typical transfer pricing guidelines, the arms lens principle and analysis analysis that we use to perform. So, this scenario increases the compliance burden for both taxpayers and tax administrations. Also, another element that's interesting also to report are some of the limitations of the amount B mechanism. In fact, the simplified approach relies on some general elements. For example, the scope of amount B includes both distributors and commissioners agents, despite their different risk profiles. The economic justification for industry groupings is also not very clear. And retail activities are not taken into account also in the mechanism. The impact on tariffs also. So, all these general elements do not provide actually for really accurate approach and simplified approach. Okay, detecting a strong notice, skepticism there, and I noticed your emphasis on supposed to be simplified too. So, colour follow-up questions, does it work as an optional instrument and what does the future hold for it, in your opinion? So, the amount B guidance was incorporated in the transfer pricing guidelines, which are non-viding soft clothes in France. And France has decided not to implement a amount B yet. In fact, it published on the 23rd of July 2025, the French administration guidelines, sorry, to detail its position on the implementation of a amount B. It sets out the general principles for applying a amount B and specifies that France is not adopting the simplified approach for the time being. However, it honors its political commitment and respects the result that will be obtained when a low-capacity country will apply a amount B. And for its political commitment to apply three-communative conditions have to be met, which is that there is a bilateral agreement in force between France and the jurisdiction of the counterparty to the transaction. The transaction of the counterparty to the transaction is included on the OECD list of low-capacity countries, and the jurisdiction of the counterparty to the transaction effectively applies the simplified method. So, it's interesting to note that the French position is not isolated as it has also been adopted by Germany, Japan, Australia, New Zealand and the Netherlands, which have published administrative instructions to this effect. Conversely, the United States allows for the optional application of a amount B, and Mexico is considering its adoption. And so, for the future concerning a amount B, I think it remains subject to significant uncertainty right now, because it's true that the idea of a amount B has many positive aspects. I mean, it's a meaningful step towards simplification and predictability in transfer pricing for routine distributors, and this is something that is truly needed. However, without the support of the majority of jurisdictions, the implementation cannot really move forward. And on B will be a real simplification factor when the majority of countries will apply it. And this is because for a multinational company faced with the need to apply transfer pricing principles in some countries and the simplified method in others, it is not certain that there will be any real simplification as we said earlier. There's also another element, which is that amount B is only one element of the pillar one solution. And many countries are actually waiting for the implementation of amounts A to see what will be the overall impact of amount A and amount B before deciding to implement the amount B in the jurisdiction. So this is why I think it's full of uncertainty for now. And we'll have to wait to see what will happen. I think with amount A to understand better if amount B will be applied or not, but by a lot of jurisdictions or not. Thank you. Vittorio, could you offer perhaps an Italian angle on the pillar one? Does it agree with Verbal? Andrews just said, do you think? I totally agree. No guidance has been published by Italy yet on pillar one amount B. Nevertheless, in my view, amount B could be viewed as an opportunity as it can allow taxpayers to review their global marketing and distribution footprint, as well as their TPP policies for baseline distribution and marketing activities. And to practically check, which would be the outcome, should pillar one would be implemented. Besides this exercise, there are still certain aspects and elements that require clarifications. For instance, the OECD amount B guidance does not clarify its applicability to permanent establishments. And this is a point that should be addressed. Thank you. It's interesting to view it as an opportunity there as well. So in terms of summing up, I'd like to go around the table again and just get your thoughts on where we stand now and perhaps what you see as the outlook for transfer pricing and what practical advice you could offer to Lebanese to better manage future disputes. So Vitor, if I could stay with you first? Yes. For some of the taxpayers, transfer pricing is associated with formal requirements that must be met by a specified deadline with associated violations for non-compliance. However, transfer pricing is not a formal compliance exercise. It's a crucial aspect of management control that impacts profitability, performance evaluation, and overall strategy. And TP as a precise lifecycle, because it starts with strategy and price setting. It continues with monitoring and adjustments, and it only ends with TP documentation, which is the very last step. So my advice is to review and refresh the functional analysis of intercompany transactions. If not every year, often involving the management control area and senior positions of the relevant departments, including HR and sales and legal, which were mentioned earlier by moment. The advice is also to review and refresh the terms and conditions of the underlying agreements with the legal department and to establish a mechanism to actively monitor and document any changes to intercompany transactions, which is very key point. In Italy, it is, of course, the advice to prepare the TP documentation, which is not mandatory, as mentioned earlier. And also, the advice should be to carefully verify consistency among different local files of the group, where entities have similar functions or risks, because from discrepancies could arise additional risks. TP should be used to proactively control the distribution of profits within the group through the year, enabling the entities to achieve arms-land profit ranges for each type of transaction and a transfer pricing method. OK, thank you. Mohammed, what would your key takeaways be for all listeners, though? Yeah. As indicated by Victoria, I think we have to refresh the functional analysis frequently to rethink the position and the analysis of the value chain within the group to be prepared. And the best manner to do it is to update TP documentation, economic analysis, to have an external view of these documents, even these documents are prepared in house. I think that another view through an assistance of a tax lawyer or law office is very important, because as we are always working with the tax administration, we have a lot of experience. And we could have some good arguments and maybe another way to present things in order to mitigate the list. So two views are better than one. So I think that groups should work closely with their tax advisor and prepare their documentation carefully and to be in a position to provide all the elements that would be required by tax and administration a case of tax audit. Thank you. So getting that second pair of eyes could be all important in risk mitigation. Andrea, finally, could I come to you here following on from Victoria and my hammered comments? Yes, thank you. So I agree with my colleagues. So in my opinion, businesses must adopt a proactive approach to securing the transfer-preasing policy. So it's becoming more and more essential for companies to develop relevant security strategy that would consist in carefully preparing its documentation for the relevant jurisdictions, having up-to-date comparable studies and checking regularly that there are no new transactions or that transactions are being implemented as planned. And finally, businesses are increasingly seeking certainty on their transfer-pricing positions to facilitate more predictability. This is evidenced by a surge in levels of interest in adress pricing agreements and dispute resolution programs offered by tax administrations. And I think that this proactive approach would also allow for more certainty and transfer-pricing. Excellent. Thank you. So you've all taken slightly different angles to in terms of the takeaways for our audience. So that's great to hear. Thank you to all of you for joining us today from CMS, David Toru, Mohammed, Alan Dreyer. And most importantly, thank you to you for listening. And have a good day. Thank you very much. Goodbye. [MUSIC PLAYING]