TRANSFER PRICING

•Preparation of transfer pricing documentation as per local regulations.
•Ensuring that all intercompany transactions (e.g., sales of goods, services, royalties, loans) are documented.
•Risk assessment to identify potential transfer pricing risks.
•Benchmarking studies using external databases to ensure arm’s length pricing.
•Compliance with OECD and country-specific guidelines (e.g., US IRS, BEPS action plans).

•Preparation of transfer pricing documentation as per local regulations.
•Ensuring that all intercompany transactions (e.g., sales of goods, services, royalties, loans) are documented.
•Risk assessment to identify potential transfer pricing risks.
•Benchmarking studies using external databases to ensure arm’s length pricing.
•Compliance with OECD and country-specific guidelines (e.g., US IRS, BEPS action plans).

•Strategic advisory on tax-efficient supply chain and pricing structures.
•Evaluating different business models (e.g., principal structures, contract manufacturing, distribution models).
•Planning around specific transactions such as IP transfers, financing, management fees, and royalties.

•Negotiating APAs with tax authorities to agree on transfer pricing methods for future transactions.
•Unilateral, bilateral, and multilateral APA discussions.
•Risk mitigation by locking in pricing methodologies for intercompany transactions.

•Assistance in managing audits or disputes with tax authorities regarding transfer pricing matters.
•Representing clients during transfer pricing audits.
•Resolving disputes through litigation support, arbitration, or mediation.
•Advising on potential risks and defensive measures.

•Pricing of loans, guarantees, and other financial transactions between related entities.
•Evaluating debt capacity and interest rates in line with arm’s length principles.
•Compliance with BEPS guidelines, including anti-avoidance rules related to thin capitalization and base erosion.

•Pricing the transfer or licensing of intellectual property (e.g., patents, trademarks, copyrights).
•Valuation of IP for purposes of intercompany transactions, especially in cross-border transfers.
•Compliance with the OECD guidelines on hard-to-value intangibles (HTVI).

•Pricing of intercompany services such as management services, administrative support, R&D, and shared services.
•Determining arm’s length charges for centralized or decentralized functions.
•Documentation of services rendered and cost allocation.

•Structuring and pricing of cost-sharing arrangements for joint development of intangibles (e.g., R&D services).
•Ensuring that contributions to the CSA are aligned with expected benefits.
•Ongoing evaluation and adjustments for changes in contributions or benefits.

•Preparation of the CbC report in line with OECD BEPS Action 13.
•Ensuring that the data reported reflects a company’s global allocation of income, taxes, and economic activities.
•Assessing consistency between the Local File, Master File, and CbC report.

•Monitoring and managing transfer pricing policies on an ongoing basis.
•Designing systems for real-time adjustment of intercompany pricing.
•Automating compliance through software solutions and data analytics.

•Identifying potential transfer pricing risks in the current intercompany structures.
•Assessing changes in local or international transfer pricing regulations.
•Mitigating risk through documentation, compliance checks, and strategic adjustments.

•Addressing challenges in pricing intercompany transactions for digital services, online platforms, and cross-border e-commerce.
•Compliance with evolving international tax rules around the digital economy (e.g., OECD Pillar One and Two).

•Developing and implementing a global transfer pricing policy across various jurisdictions.
•Ensuring consistent and compliant pricing for intercompany transactions.
•Coordination between tax and finance functions to ensure transfer pricing strategies are embedded in the global operating model.

•Advising on transfer pricing aspects during mergers, acquisitions, and divestitures.
•Ensuring that transfer pricing policies align with post-acquisition integration or restructuring.
•Valuation of intercompany assets, liabilities, and functions transferred during M&A transactions.