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Transfer Pricing

Transfer pricing strategy involves billions-dollar impact on corporations doing business worldwide and, therefore, tax authorities are increasing their scrutiny and enforcement. Your company may need to get a complete and practical analysis of the latest transfer pricing regulations, including cost sharing, valuation of tangible and intangibles, and audit strategies to avoid tax penalties and substantial tax adjustments.

• General Services

Our experts work together with our client to:

• Review and analyze the latest development of principles and guidelines
• Perform analysis on functions for pricing
• Assess risks and its consequences
• Working for optimization
• Consider arms-length range and apply comparables parameters
• Analyze on operation data and implement strategies

• Advance Pricing Agreement

Consider an advance pricing agreement (APA) which may reduce your risk of tax audit. The APA Program introduced by tax authority is designed to resolve potential transfer pricing disputes in a guided and cooperative manner instead of an adversarial negotiation environment.

To achieve a successful negotiation of an APA, we can assist you to:

• Develop an appropriate transfer pricing methodology and APA strategy
• Negotiate with the tax authorities on the proposed methodology and APA application
• Preparation and lodging of formal APA application
• Advise on the implementation and review on the compliance of the APA

• Cost Sharing Arrangement

We help to document, whether in form of agreement or otherwise, and work out the details on accounting practices and valuation related to the asset employed as well as details of expected and actual benefits for considering necessary of adjustments for differences to be made.

• Compliance & Dispute Resolution

Managing transfer prices requires both the capability to implement a regulated compliant policy and to ensure that the policy is adequately implemented and appropriately managed.

We assist your company to:

• Identify and assess of the risk of challenges, and consider appropriate strategies to manage and control the changes.
• Re-structure inter-value chain and activities to integrate the business operation with overall strategy.
• Collect supporting evidence and documentation for managing an audit defence.
• Reply to the challenges of tax authorities and negotiate for settlement and on potential adjustments.