I have just received a TP notice. What should I do first?

Note the reply date, collect your TP study and financials, and speak to an SBC litigator. They will walk you through the issues, the amount at stake and the evidence you still need.

Can you tell me how strong my case is?

An SBC litigator maps each issue to the evidence you hold and to the responses that usually succeed. The view on strength comes from a person, not software.

Do you handle DRP and Tribunal appeals?

Yes. SBC International Tax Practice drafts, files and argues objections and appeals before the DRP and the Income Tax Appellate Tribunal.

Do you support UAE Corporate Tax disputes?

Yes: FTA audits, reconsideration requests and objections before the Tax Disputes Resolution Committee.

When will the TAIGA litigation modules be available?

They are in development. Join early access and we will show you each module as it is ready.

Book a demo

Transfer pricing litigation · SBC International Tax Practice

From the first notice to the final order, argued for you.

SBC International Tax Practice represents you at every stage: before the TPO, the DRP, the ITAT and the UAE Federal Tax Authority, with support for MAP and APA negotiations.

In developmentTAIGA's litigation modules will read the notice, track every clock and draft from your own data.

Speak to a TP litigator Join early access

India · UAE
TPO, DRP, ITAT and FTA matters
taxtech500 · 1st Place
TP Suites and TP Documentation Software, every month Mar–Oct 2026
IFLR Middle East Awards 2026
Tax Innovator of the Year UAE

01 / Why TP disputes are lost

Most TP cases are not lost on law. They are lost on time, on evidence and on a file written for compliance, not defence.

Clocks run out

Notices arrive in sequence. Replies, objections and appeals each have their own window.

Issues hide in the notice

A long notice can bury the one adjustment that drives most of the tax.

Positions drift

Arguments made to the TPO are not carried cleanly to the DRP and the Tribunal.

Counter-numbers come late

The taxpayer's own comparable set and range are rarely recomputed before the hearing.

02 / The dispute path

Every stage, every clock. Pick a stop to see what happens there.

Either

Reference to the TPO

The Assessing Officer refers the international transactions to the Transfer Pricing Officer.

In developmentTAIGA will record the notice number, assessment year, issues, status and next deadline at this step.

03 / What TAIGA is being built to do

Seven modules, one case file.

In development

Notice & Order Intelligence

Reads the notice or order behind a redaction gate and produces a Health Check: issues, amounts at stake, deadlines and missing evidence.

Issue Drill-down

Breaks each adjustment into its building blocks (comparables, filters, working capital, risk, method choice) with the strongest response for each.

Range Counter-computation

Rebuilds the comparable set and recomputes the arm's length range and percentiles under the Indian rules.

Submission Studio

Drafts replies in two modes: rapid, for tight hearing dates, and comprehensive, for DRP and Tribunal filings.

Document Forge

Adjournment letters, grounds of objection and appeal, paper-book indexes and synopses.

Knowledge Navigator

Asks clarifying questions first, then answers with the authority behind each point.

Litigation Command Centre

One register for every matter: notices, hearing dates, filings, owners, and reminders the day before and on the day.

Matter	Stage	Next date
Entity A · AY 2022-23	DRP objections	Hearing in 3 days
Entity B · AY 2023-24	TPO submissions	Reply in 9 days
Entity C · FY 2024	FTA reconsideration	Filing in 21 days

04 / Issues we answer most often

The adjustments that come up, again and again.

India

Rejection or inclusion of comparables, and the filters used
Working-capital and risk adjustments
Most appropriate method and profit level indicator
Intra-group services: benefit test, cost allocation, shareholder activity
Marketing intangibles and AMP spend
Interest on receivables, corporate guarantees and intercompany loans
Royalty and fees for technical services
Segmentation of financials and multiple-year data

UAE

Arm's length testing under Article 34
Documentation under Article 55
Connected-person payments

05 / People and technology

SBC argues the case. TAIGA will prepare the file.

Representation, today

SBC International Tax Practice argues before Transfer Pricing Officers, Dispute Resolution Panels, the Income Tax Appellate Tribunal and the UAE Federal Tax Authority, and supports MAP and APA negotiations.

TPO
DRP
ITAT
UAE FTA
MAP
APA

In development

The case file, prepared by TAIGA

The modules above will read the notice, break down each issue, recompute the range and draft the submission, for an SBC litigator to review and argue.

Redaction gate

Notices and financials are redacted before analysis.

TAIGA Seal

Each report carries a unique number, timestamp and code that traces it to its matter.

06 / Questions

Frequently asked.

Got a TP notice? Know where you stand.

Bring the notice. An SBC litigator walks you through the issues, the money at stake and the clock you are on.

Speak to a TP litigator Join early access

If it's TP, it's SBC.

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