More companies are looking to make deals with tax authorities on transfer-pricing terms to avoid unexpected penalties, tax advisers report.

While most professional service providers are struggling, transfer pricing has been an area that is seeing tremendous demand in the market. The tax authorities are looking to offset revenue decreases due to a bad economy from more aggressive international tax audits, often resulting in significant adjustments and penalties.

While a lot of this aggressive behaviour can be labelled "getting our fair share" much of it is unnecessarily aggressive and unreasonable. How do you safeguard against the taxman?