Inconsistent tax transfer prices: tax filings, audits, and double taxation

There is no market price for cross-border intercompany transactions. In order to be able to correctly allocate taxable income and expenses to the countries involved, a proxy is therefore required: the so-called tax transfer price. The aim of the survey is to obtain an overview: When do deviations occur (do companies anticipate the problem and already report deviating transfer prices in their tax returns? Or do deviations only occur as a result of a tax audit?)? What are the consequences of these deviations (reduced taxation or double taxation)? Can double taxation be prevented through mutual agreement procedures? Which countries are particularly vulnerable to induce transfer pricing inconsistencies?