International Taxation

TRANSFER PRICING

In an increasingly global business environment, fiscal authorities vigorously defend their national tax bases with detailed transfer pricing regulations, strict documentation requirements, sophisticated audit practices and significant penalties for non-compliance.

Multinationals must be able to present clear arguments to support transfer pricing decisions because the tax authorities reviewing a cross-border related party transaction might not agree on an appropriate ‘arm’s length’ price. The decisions organizations make must be substantiated by authoritative analysis and a good understanding of the local rules governing their transactions.

Forward-thinking companies recognize that effective global transfer pricing policies must do more than simply enable them to comply with national rules. They know transfer pricing issues have to be addressed long before transactions actually occur and they try to make their transfer pricing policies into strategic tools for investment and supply chain decisions, as well as for global tax planning.

We provide advice in the following areas:

  • Planning — we help multinationals develop and implement commercially sensible, fiscally efficient transfer pricing policies and modify existing policies to reflect changes in local law or business circumstances. We help companies assess the impact of transfer pricing policies on their overall tax position.
  • Compliance and documentation — we help multinationals design and implement global compliance policies and procedures and prepare local documentation for a strong, first line defense against tax authority challenges.
  • Implementations — we help multinationals translate their transfer pricing policies into transaction-level prices, reconcile transfer pricing and customs requirements and automate transfer pricing calculations. We also help companies test and report transfer prices and develop processes and tools to monitor transfer pricing results.
  • Dispute resolution — when tax authority challenges arise, we can help companies respond with detailed, authoritative economic justifications for existing transfer prices including Dispute Resolution Panel proceedings.
  • Alternative dispute resolutions — we help multinationals assess and manage their transfer pricing risk factors and pursue bilateral or multilateral Advance Pricing Agreements (APAs) or Competent Authority negotiations.
  • Mutual agreement procedure
  • Advance pricing arrangement.

OTHER SERVICES:

Global companies require global tax planning. It is not enough for a multinational company to adapt separately to each of its local operating environments. To take account of local, regional and national factors — and to thrive — a successful multinational company needs to adapt to all its environments. Tax is one of the most important environmental variables because it helps determine what kind of corporate structure is appropriate, where intellectual property should be located and how global supply chains should be configured to help mitigate overall effective tax rates.

  • Our professionals have the technical knowledge and experience to help organizations seize tax opportunities and avoid pitfalls.
  • Foreign tax credit tax advice
  • Cross-border structured finance tax advice Compliance and planning assistance in relation to international trade and customs issues
  • Advice on global indirect taxes
  • Valuations and other economic analysis Our professionals seek to exemplify the principle ‘think globally, act locally’.

We keep our clients informed of current tax thinking and technical developments