Transfer Pricing

Balancing Risk & Opportunity

Transfer Pricing is one of the most important and complex aspects of international taxation. Recent initiatives, such as the OECD/G20 BEPS-project and changes to domestic transfer pricing rules, show the continued focus on how intercompany transactions should be priced.

In this context, we help you:

• Align your transfer pricing outcomes with value creation
• Maintain a pragmatic, efficient and effective transfer pricing system
• Reduce the risk of transfer pricing adjustments and penalty assessments by tax authorities
• Minimize the risk of the same income being taxed twice

We are specialised in:

• Reviews and Risk Assessment: we review your current transfer pricing position, identify potential risks and recommend practical ways to address them.
• Transfer Price Planning: we help you transfer prices that are compliant with the applicable laws and practices, while supporting your business and tax objectives.
• Policy Design: we assist you in developing robust and efficient transfer pricing policies and help you implementing them.
• Documentation and Reporting: we prepare the documentation needed to support your transfer prices and help you meet reporting obligation, including Country-by-Country Reporting.
• Advance Pricing Agreement and Ruling: we work with you to define the right strategy to obtain advance certainty of your transfer price approach
• Dispute Resolution: we help you in dealing with tax authority enquiries, tax audits, tax courts proceedings and mutual agreement procedures.