Cross-border transactions between related companies are increasing in number and complexity as multinationals search for more efficient ways to compete in the global market.
Growing concerns over the impact of transfer pricing on local tax revenues have resulted in a strengthening of legislation in many jurisdictions. Changes include stricter documentation requirements and penalties for non-compliance.
As legislation on global transfer pricing evolve, astute businesses have begun undertaking regular reviews of their cross-border activities.
We can help you avoid inadvertent errors that may cost you your business.
We believe that any transfer pricing exercise must be based on sound and defensible principles.
In addition, your business objectives and operational requirements must be mapped to prevailing legislations across jurisdictions to determine the impact on your business activities.
The pricing model developed will thus help you achieve tax efficiencies and is likely to be relatively unchallenged by tax authorities.
We also believe that a multi-disciplinary approach is the best. And that is why our transfer pricing team comprises seasoned economists, tax practitioners, lawyers, accountants and financial analysts who can give you the incisive advice you need.
Our teams of transfer pricing specialists, including Partners/Directors, are based in significant jurisdictions around the world and they stand ready to assist you. They can help you:
- develop and implement commercially and fiscally viable transfer pricing policies
- minimize effective tax rate internationally through transfer pricing planning
- comply with local transfer pricing requirements including preparation of documentation and supporting intercompany agreements
- defend existing transfer pricing policies and practices against challenges from tax authorities
- evaluate and quantify transfer pricing risk arising from compliance with reporting of uncertain tax positions
- prepare and negotiate advance pricing agreements with tax authorities to cover future transfer prices
- conduct due diligence in relation to your potential acquisitions
- resolve double taxation from mutual agreement procedures