Virtual Tax Advisory Services
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Transfer Pricing

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Transfer Pricing Documentation And Compliance

We assist multinational companies in preparing comprehensive transfer pricing documentation to comply with local and international regulations. Our services include:

01

Master Files

Preparing Master Files that provide an overview of the multinational group’s global business operations, transfer pricing policies, and financial results. This includes detailed information on the group’s organizational structure, business activities, intangible assets, intercompany financial activities, and overall financial performance.
02

Local Files

Creating Local Files tailored to the specific requirements of each jurisdiction, detailing the local entity’s operations, relevant intercompany transactions, and the arm’s length analysis supporting the pricing of those transactions. This documentation ensures that local tax authorities have the information needed to evaluate the compliance of the local entity with transfer pricing rules.
03

Country-By-Country Reports (CbCR):

Preparing CbCRs that provide a high-level snapshot of the allocation of income, taxes paid, and business activities of the multinational group across different countries. This report is essential for tax authorities to perform risk assessments and ensure that profits are appropriately allocated in accordance with economic activities.

Transfer Pricing Planning And Strategy

Our experts help clients develop effective transfer pricing strategies that align with their business operations while ensuring compliance with OECD guidelines and local regulations. Services include:

01

Functional And Economic Analysis

Conducting detailed functional and economic analyses to understand the value drivers of the business and the roles of various entities within the multinational group. This helps in identifying appropriate transfer pricing methods.
02

Benchmarking Studies

Performing benchmarking studies to identify comparable transactions or companies and establish arm’s length pricing for intercompany transactions. These studies support the justification of transfer prices to tax authorities.
03

Policy Development

Assisting in the development of transfer pricing policies that reflect the commercial realities of the business and align with regulatory requirements. This includes setting transfer prices for tangible goods, services, intangibles, and financial transactions.
04

Risk Assessment

Evaluating transfer pricing risks and providing recommendations to mitigate potential issues, including structuring transactions and operations to optimize tax positions while maintaining compliance.

Dispute Resolution and Advance Pricing Agreements (APAs)

We represent clients in transfer pricing disputes with tax authorities and assist in negotiating and obtaining APAs to provide certainty on transfer pricing methods for future transactions. Our services include:

01

Dispute Resolution

Representing clients in transfer pricing disputes, including audits and litigation, by preparing robust defense documentation and engaging with tax authorities to resolve issues amicably.
02

Advance Pricing Agreements (APAs)

Assisting clients in negotiating APAs with tax authorities, which provide advance approval of transfer pricing methods for specified transactions over a fixed period. This ensures certainty and reduces the risk of future disputes.
03

Mutual Agreement Procedures (MAPs)

Facilitating the resolution of international tax disputes through MAPs, which involve negotiations between tax authorities of different countries to resolve issues of double taxation arising from transfer pricing adjustments.
04

Strategic Advice

Providing strategic advice on managing and resolving transfer pricing disputes, including evaluating the merits of various dispute resolution mechanisms and selecting the most appropriate approach for the client’s specific situation.

Through our transfer pricing services, we help multinational companies manage their transfer pricing risks, ensure compliance with global regulations, and optimize their tax positions while maintaining operational efficiency.

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