TRANSFER PRICING ADVISORY AND VALUE CHAIN OPTIMISATION
WITH SPECIFIC FOCUS ON SUPPORTING THE SUBSTANCE OF ARRANGEMENTS
DOCUMENTATION & BEPS /
FINANCING, DEBT PRICING AND THIN CAPITALISATION
TRANSFER PRICING IMPLEMENTATION AND
COMPLIANCE MANAGEMENT SYSTEMS
DISPUTE RESOLUTION AND APAs
Risk Assessment, including high-level review of inter-company business model and pricing arrangements to ensure alignment with transfer pricing requirements.
Value Chain Optimisation and Business Restructuring, is often an ongoing activity within a global business. It may involve centralisation of procurement, moving production to lower cost countries, relocating senior management or integrating acquisitions. Aligning transfer pricing outcomes with business changes and commercial imperatives is essential.
Documentation Support, utilising latest technologies to assist in preparation of transfer pricing documentation to mitigate against penalties and comply with local regulations across multiple jurisdictions.
Complying with BEPS requirements, including CbCR, is a necessary compliance burden which requires careful management and navigation from a global perspective. Global businesses may be required to prepare CbCR, master file, local file, specific country reports and notifications. In addition, businesses should carefully review, assess and address the risks and opportunities highlighted from these various transparency measures.
Financing and Debt Structures, including preparation of supporting documentation which can be used to support group positions in the face of challenge from tax authorities.
Thin Capitalisation, requires comprehensive analysis to bring certainty to complex financing structures on their tax treatment by tax authorities.
Governance and Risk Management, to ensure there are systems and processes in place to manage transfer pricing risk and demonstrate good governance
frameworks expected by tax authorities and Boards.
Dispute Resolution, including audit defence, representation before tax authorities, mutual agreement procedures and negotiating outcomes.
Advance Pricing Agreements (APAs), assist in negotiation of unilateral or bi/multi-lateral APAs to increase tax certainty.
Our transfer pricing services
Our transfer pricing services can be split into five key areas: