Transfer pricing

We help you design transfer pricing policies that align with the value drivers of the business, maximizing the efficiency of outcomes. Our services include:

• Transfer pricing advisory and planning: Structuring, characterization, pricing and benchmarking of new intercompany transactions
• Transfer pricing risk analyses: Transfer pricing health checks
• Transfer pricing policy design: Designing sustainable transfer pricing policies
• Value chain realignment: Reviewing whether your current transfer pricing mechanisms are fit for purpose and recommending changes

We help you integrate transfer pricing policies within your internal systems to achieve seamless execution of policy design / outcomes and avoid year-end surprises. Our services include:

• The design of user manuals
• Design of data extraction templates for the seamless application of transfer pricing policies
• Intercompany agreements assistance, providing agreement review or heads of terms that are important from a transfer pricing and general tax perspective

We help you prepare and submit three-tiered transfer pricing documentation. Our services include:

• Local files
• Master files
• Country-by-country reports and notifications

We help you navigate transfer pricing controversy. Our services include:

• Transfer pricing inspection support: Studying your transfer pricing documentation and supporting your company position through writing defense memos and liaising with the transfer pricing unit during inspections
• Advance Pricing Agreement (APA) applications and maintenance