Transfer Pricing
Advisory services for structuring related-party transactions in a compliant, defensible manner consistent with commercial realities.
Scope
Service Scope
Related-party transaction analysis
Intragroup goods, services, financing, intangible assets, cost sharing and other transactions are reviewed to identify transfer pricing risk areas.
Benchmarking studies
Appropriate methods are selected for each transaction type, and benchmarking analyses are prepared using domestic and international data sources.
Transfer pricing documentation
Required documentation is prepared for annual transfer pricing reports, master files and country-by-country reporting obligations.
Intragroup agreement and policy review
Related-party agreements and pricing policies are assessed against tax legislation, OECD guidelines and commercial practices.
Tax audit and dispute support
Support is provided in transfer pricing audits for technical defense preparation, document management and communication with tax authorities.
Deliverables
Deliverables and References
Transfer pricing risk map
Prioritized tax risks and action areas by related-party transaction.
Annual transfer pricing report
Audit-ready transfer pricing documentation in compliance with local requirements.
Benchmarking analysis file
Technical analysis covering the selected method, comparable companies or transactions and financial results.
Policy and agreement recommendations
Legally compliant recommendations to improve intragroup pricing policies and agreements.
Management presentation
Decision-support presentation summarizing risks, findings and recommended actions for senior management.
Our Process
How We Work
Preliminary assessment
The corporate structure, related-party transactions, existing reports and agreements are examined to establish the scope of work.
Functional and risk analysis
Functions performed, assets used and risks assumed by the parties are analyzed to establish economic substance.
Benchmarking and method selection
The most appropriate transfer pricing method is selected for each transaction type and comparability analysis is performed.
Reporting and action plan
Findings are reported, recommendations are provided for compliance gaps and an actionable plan is prepared.
Industries
Advisory That Understands Your Industry
Our specialists understand the tax, audit and operational needs of each industry.
Related Specialists
Specialists Working with This Service
Raising the bar
in advisory and audit.
We are a strategic partner to more than 700 organisations, delivering practical, tailored solutions to international standards.
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