Policy Development: Creating transfer pricing policies that align with the company’s business model and operational strategy, ensuring they meet regulatory requirements.

Operational Implementation: Assisting in the practical application of transfer pricing policies, including the setting of transfer prices, monitoring of transactions, and maintaining compliance.

Conducting transfer pricing benchmarking analyses to identify comparable companies and transactions, helping to determine arm’s length prices for intercompany transactions.

We have access to a wide variety of transfer pricing databases, such as, TP Catalyst, Osiris, Compustat, Royalty Stat, Royalty Source, ktMINE, Loan Connector, Bloomberg, Eikon, Lipper etc.

Master File and Local File Preparation: Ensuring compliance with OECD guidelines and local regulations by preparing comprehensive documentation that details the company’s transfer pricing policies, financial information, and functional analyses.

Country-by-Country Reporting (CbCR): Assisting with the preparation and filing of CbCR and CBCR notifications, which provides tax authorities with an overview of the allocation of income, taxes, and business activities by tax jurisdiction.

Transfer Pricing Risk Reviews: Evaluating existing transfer pricing practices to identify and mitigate potential risks (e.g., at a due diligence).

Audit Defense: Providing support during tax audits, including preparation of audit documentation, negotiation with tax authorities, and dispute resolution.

Assisting in the negotiation and implementation of APAs with tax authorities to obtain advance approval of transfer pricing methods, providing greater certainty and reducing the risk of future disputes.

Advising on the appropriate pricing of intercompany loans, guarantees, and other financial transactions to ensure they are consistent with the arm’s length principle.

Assets/Business Valuation: Valuing intellectual property, business transfers and other intangible assets for transfer pricing purposes, ensuring compliance with relevant guidelines.

Business Restructuring: Valuing assets and determining the transfer pricing implications of business restructurings and reorganizations.

Training Programs: Offering customized training sessions for in-house tax and finance teams to enhance their understanding of transfer pricing principles and compliance requirements.

Ongoing Support: Providing ongoing advisory services to address day-to-day transfer pricing issues and updates on regulatory changes.