Our variety of consultation on transfer pricing
Tax authorities want to ensure profits are taxed where the value is created. The new rules are being introduced from 2016 and they relate, in practice, to documentation and evidence that companies are complying with transfer pricing principles in whichever countries they operate. That has further increased scrutiny on transfer pricing on multinational companies.
Every international business must give its transfer pricing policy and compliance significant care and attention. Businesses should have transfer-pricing documentation in place to articulating the alignment between value creation and where profits are taxed. In addition, you should regularly review and update transfer pricing policies to reflect commercial and operational changes.
Failing to manage transfer pricing effectively and periodically can lead to:
– Tax audits and reassessments, with the potential for penalties and interest
– Double taxation in multiple territories with no relief available under tax treaties
– Costly and time-consuming dispute with tax authorities
– Reputational damage to brand and business
The experienced professionals of Premier Tax & Advisory is ready to meet your domestic and global transfer pricing needs. We have extensive experience advising a lot of businesses including multinational organizations through all aspects of their transfer pricing issues; planning, implementation, documentation, and controversy.
Our team can proactively advise on how to best structure the related-party transactions and design, implement, and document a transfer pricing policy that makes sense for your business. Our transfer pricing professionals help you develop transfer pricing policies that maximize potential for increasing your after-tax income, while minimizing the likelihood that you will be subject to tax adjustments and penalties.
We also help you ensure that your transfer pricing policy is practically and properly aligned with regulations as well as your business operations.
Transfer pricing dispute resolution
Despute resolution on transfer pricing can become a long and costly dispute. Our extensive experience of interacting with tax authorities across the globe enables us to adapt our approach to specifically meet the requirements of the relevant territory on a case by case basis.
■ Advanced Pricing Agreements (APAs)
We have successfully obtained Advanced Pricing Agreements (APAs) in a number of territories and can assist you throughout the process.
■ Mutual Agreement Procedure (MAP)
MAP is a process that authorises tax authorities to communicate with each other directly for the purpose of resolving the issue and avoiding double taxation. We have in-depth experience of the MAP application and negotiation process and can support you to seek a satisfactory resolution to any tax authority dispute.
Examples of our services
■ TP risk assessment and policy development
- Transfer pricing analysis / risk assessment in the transactions
- Review and design transfer pricing policies for the future
- Group/Value chain transformation, global business model optimization
- Transfer pricing on business transfer / Intellectual property transfer
- Transfer pricing arrangement of intra-group services
- Transfer pricing arrangement of intra-group financing; intra-group loans, guarantees and captive insurance
- Related-party agreements and contracts – review and advice
- Support implementing transfer pricing policies including setting prices and monitoring
- Inter-company donations under the Japanese tax legislations
- BEPS Action 13 compliance – Local File, Master File and CbCR
- Annual renewal of documents and benchmarking studies
- Dispute avoidance: Advance Pricing Agreements (APAs)
- Tax audit defense and communication with Japanese Tax Authorities
- Dispute resolution: Mutual Agreement Procedure (MAP) / Administrative appeals