TP — DRP Proceedings
Objecting to a proposed transfer pricing adjustment before the Dispute Resolution Panel.
Where a Transfer Pricing Officer proposes an adjustment, the taxpayer can file objections before the Dispute Resolution Panel (DRP) within the prescribed time, instead of waiting for the final assessment order. The DRP reviews the draft order, the TPO's findings, and the taxpayer's objections, and issues binding directions to the assessing officer. This route offers a faster, specialised alternative to a regular appeal at the first level of dispute.
What DRP representation involves
DRP objections need to be filed within a strict window and argued on both facts and law.
- Reviewing the draft assessment order and proposed adjustment
- Preparing detailed objections within the statutory time limit
- Compiling supporting evidence, case law and prior-year precedents
- Representing the case in DRP hearings
- Reviewing DRP directions and their implementation by the assessing officer
- Advising on further appeal if the outcome remains unfavourable
What this service includes
How we support you through DRP proceedings.
Draft Order Review
Analysing the TPO's draft order to identify the strongest grounds for objection.
Objection Drafting
Preparing comprehensive, well-referenced objections within the filing window.
Case Law & Precedent Research
Building the legal argument with relevant judicial and tribunal precedents.
DRP Hearing Representation
Presenting the case directly before the panel.
Our process
From initial consultation to completion.
Draft Order Analysis
Reviewing the proposed adjustment and the TPO's reasoning in detail.
Objection Preparation
Drafting objections supported by facts, documentation and precedent.
Panel Hearing
Representing the case before the Dispute Resolution Panel.
Directions Review
Assessing the DRP's directions and advising on implementation or further appeal.
Why the DRP route is worth considering
What sets our approach apart.
A faster, specialised alternative to a first appeal
DRP proceedings are designed to resolve disputes without waiting through the standard first-appellate timeline.
Directions are binding on the assessing officer
Once issued, DRP directions must be implemented, giving the process real teeth.
Strict filing timelines leave no room to delay
Objections must be filed within a short statutory window from receipt of the draft order, so early preparation is essential.
TP DRP proceedings questions answered
What people ask before engaging us.
