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Earth with Data Connections

Navigating Global Complexity: Expert Transfer Pricing Services

Transfer pricing – the pricing of goods, services, and intangibles between related entities – is a critical area of focus for tax authorities worldwide.

What is Transfer Pricing?

Transfer pricing refers to the rules and methods for pricing transactions within and between enterprises under common ownership or control. The internationally accepted standard for transfer pricing is the Arm's Length Principle. This principle states that the price charged between related parties should be the same as if the transaction had occurred between unrelated parties under comparable circumstances.

Why is Transfer Pricing Critical for Your Business?

  • Compliance: Adhering to complex and evolving local and international transfer pricing regulations (e.g., OECD Guidelines, BEPS Actions) is mandatory.

  • Risk Mitigation: Proactive transfer pricing management minimizes the risk of tax audits, adjustments, interest, and substantial penalties.

  • Avoid Double Taxation: Proper transfer pricing helps prevent the same income from being taxed in two or more jurisdictions.

  • Operational Efficiency: Well-designed transfer pricing policies can align with your business model, improve operational efficiency, and provide performance measurement clarity.

  • Strategic Planning: Effective transfer pricing can support global tax planning and value chain optimization.

Our Comprehensive Transfer Pricing Services

Transfer Pricing Planning & Policy Design

  • Developing and implementing commercially sound and defensible transfer pricing policies.

  • Structuring intercompany transactions in line with the arm's length principle.

  • Advising on the transfer pricing implications of business restructurings, mergers, and acquisitions.

Transfer Pricing Documentation

  • Preparation of robust Master Files, Local Files, and Country-by-Country Reporting (CbCR) in compliance with OECD BEPS Action 13 and local requirements.

  • Ensuring documentation provides a clear narrative and strong defense of your transfer pricing positions.

Benchmarking

Studies

  • Conducting thorough comparability analyses using leading databases.

  • Determining arm's length ranges for intercompany transactions (e.g., tangible goods, services, financing, royalties).

Risk Assessment & Audit Defense

  • Reviewing existing transfer pricing policies and documentation to identify risks and areas for improvement.

  • Assisting in managing transfer pricing audits and responding to tax authority inquiries.

  • Supporting dispute resolution through Mutual Agreement Procedures (MAPs).

Advance Pricing Agreements (APAs)

  • Assisting with negotiation and conclusion of unilateral, bilateral, and multilateral APAs.

  • Providing certainty on transfer pricing methodologies for future transactions.

Implementation & Monitoring

  • Helping businesses implement transfer pricing policies within operational and financial systems.

  • Periodic review and updates of policies and documentation to reflect changes in business or regulations.

Earth from Space View

Value Chain Analysis (VCA) / Business Model Optimization (BMO)

  • Analyzing your global value chain to align transfer pricing with value creation.

  • Identifying efficiencies and managing tax risks effectively.

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