Transfer Pricing

It is more crucial than ever to have an efficient strategy for managing transfer pricing possibilities, compliance, and risk in the ever evolving world of transfer pricing.

Transfer pricing has gained significant attention in the area as a result of the OECD’s BEPS Action Plans, particularly since the Kingdom of Saudi Arabia and Egypt released comprehensive transfer pricing rules. Furthermore, as more countries join and implement the BEPS Inclusive Framework, groups with regional headquarters must stay up to date with the quickly changing transfer pricing landscape in the jurisdictions where their group entities and business presence are located. This is especially important in light of the requirements for Country by Country reporting and notification that are emerging in these jurisdictions.

  • Discussing the end-to-end process with Heads of Departments (HODs) Review of the complete process’s documentation trail.
  • Suggesting areas where the VAT may have an influence, such as adjustments to roles and responsibilities or documentation.

How are we able to assist?

Transfer Pricing Risk assessment

Not every intragroup transaction is made with the intention of evading tax payment. We support multinational enterprises (MNEs) in mitigating their transfer pricing risks by fortifying their transfer pricing documentation and gaining increased confidence about their tax and transfer pricing stances in accordance with both domestic and globally recognized transfer pricing regulations and standards.

Transfer Pricing Planning

We assist clients in creating and putting into practice transfer pricing policies for both planned and ongoing intragroup transactions. We also document policies and results that support the achievement of business and commercial goals while lowering the possibility of adjustments and fines from tax authorities during audits. This comprises:

  • Creating the best possible transfer pricing strategy for deals involving different companies
  • Conducting suitable benchmarking research to determine an arm’s length pricing
  • Creating the policy document for transfer pricing to record the pricing methodology
  • Examining intercompany contracts from the standpoint of transfer pricing
  • Assisting customers with the transfer pricing policy implementation and conducting regular evaluations to find any gaps.

Transfer Pricing Documentation

When tax authorities contest a company’s transfer pricing methods, a strong and thorough documentation of transfer pricing is the first line of defense and the initial course of action.

We support clients in fulfilling international and local documentation requirements for transfer pricing. This comprises:

    • Production of local files and local transfer pricing documents in compliance with local transfer pricing legislation and the knowledge acquired from income tax and transfer pricing audits.
    • Creation of the master file in accordance with local transfer pricing regulations and OECD guidelines.
    • Reporting on a country-by-country basis, complying with notification obligations, and evaluating the exposure and transfer pricing risk for clients due to the submission of such information about international operations to tax authorities in various locations.

Transfer Pricing advisory services

We support our clients in achieving their goals and offer guidance on their unique concerns and areas of pressure, such as the following:

    • Aligning transfer pricing strategies with business goals.
    • Examine current intercompany agreements to see if the documentation may be improved for tax efficiency.
    • Transformation of the supply chain to guarantee that transfer prices reflect value generated.
    • Giving Permanent Establishments Credit for Profit.