In an increasingly global business environment, fiscal authorities vigorously defend their national tax bases with detailed transfer pricing regulations, strict documentation requirements, sophisticated audit practices and significant penalties for non-compliance.
Multinationals must be able to present clear arguments to support transfer pricing decisions because the tax authorities reviewing a cross-border related party transaction might not agree on an appropriate ‘arm’s length’ price. The decisions organizations make must be substantiated by authoritative analysis and a good understanding of the local rules governing their transactions.
We offer following services:
- we help multinationals develop and implement commercially sensible, fiscally efficient transfer pricing policies
- Transfer pricing planning and documentation
- Dispute resolution — when tax authority challenges arise, we can help companies respond with detailed, authoritative economic justifications for existing transfer prices including Dispute Resolution Panel proceedings.
- Alternative dispute resolutions — we help multinationals access and manage their transfer pricing risk factors and pursue bilateral or multilateral Advance Pricing Agreements (APAs) or Competent Authority negotiations.
- Mutual agreement procedure
- Advance pricing arrangement.