Transfer Pricing

Our professionals help you build, manage, document, review and support your transfer pricing policies and processes. We work with you to build pragmatic, integrated strategies that address the tax risks of your business and help your business achieve its potential.

We can help you with:

Oversight on the Company’s transfer pricing matters and working with multiple stakeholders to provide support on transfer pricing related issues

Handling transfer pricing analysis and reporting

Provide advice on transfer pricing implications for new business initiatives

Support transfer pricing audits, including responding to tax authorities on matters or queries relating to transfer pricing.

Managing and preparing transfer pricing documentation to support intra-group transactions in compliance with local regulations

Conducting regular internal review of transfer pricing policies in accordance with the latest tax regulation developments

Transfer Pricing Due Diligence

Why is transfer pricing due diligence important during M&A?

Due diligence presents the opportunity for an acquiring company to look at the transfer pricing policies & activities of the target company. Doing so helps identify potential risks; it also forms the basis for analyzing potential future opportunities for policy integration once the acquisition is complete.

Identifying and addressing risks early in the process allows for sufficient planning, and paves the way for a smoother integration. By anticipating future transfer pricing challenges, the acquiring company can put contingencies in the purchasing contract to account for adjustments. On the other hand, lax due diligence has a high price: It can have extensive financial implications down the line, including garnering unwelcome attention from tax authorities.

M&A Due Diligence Checklist for Transfer Pricing

If your company is planning M&A activity and you’re tasked with managing tax due diligence, following checklist might be useful to you…

Evaluate whether formal transfer pricing policies are in place.

Review the target company’s transfer pricing documentation.

Assess the target company’s country-by-country reports.

Review any existing legal agreements for intercompany transactions.

Perform in-depth analysis to determine if transfer pricing risks exist.

Transfer Pricing Designing & Structuring

We can help you with:

Strategy and policy development

Reduce the impact of year-end adjustments

Monitor your transfer pricing footprint

Global or regional assistance to support transitions to new documentation requirements

Controversy risk assessment, remediation or mitigation as a result of documentation requirements

Global transfer pricing controversy and risk management