Transfer pricing is now one of the most topical issues on the international tax agenda, especially after the OECD’s initiative “Tax Base Erosion and Profit Sharing” (BEPS), which clearly affects the activities of multinational companies.
Businesses conducting cross-border transactions are very likely to encounter transfer pricing issues, including requests from tax authorities in one or more jurisdictions.
We can help you create, manage, review and support your intercompany invoicing processes.
In particular, we offer the following services:
Documentation of intra-group transactions
Preparation of intra-group transaction documentation files for related parties in accordance with OECD guidelines and the Income Tax Rules:
- Master File
- Local File
- Summarized Table of Transfer Pricing Information
Planning of intra-group pricing policies
Planning and implementation of intra-group pricing policies aligned with a value chain analysis for domestic and multinational groups.
Establishment of policies that comply with the arm’s length principle through the proper application of the methodologies included in the OECD guidelines, allowing compliance with transfer pricing obligations in all countries in which the Group operates.
Advance Pricing Agreement (APA)
Design, submission and negotiation of unilateral, bilateral or multilateral APAs to the tax authorities involved, which allow certainty on acceptable pricing policies for international intra-group transactions, thus avoiding tax risks and potential cross-border disputes under Transfer Pricing.
Support with tax procedures
In coordination with your tax advisors, we provide defense of transfer pricing positions and policies during tax audits, tax appeal procedures (financial-administrative claims and disputed-administrative appeals) or Mutual Arrangement Procedures (MAP’s).
Country by Country report
Country-by-country reporting (CbCr) is an important tool for tax authorities to achieve greater transparency. This contributes to the prevention of potential regulatory penalties, as it allows you to understand key aspects of CbCr and the compliance requirements.
Other services
Documentation of intra-group transactions
Preparation of intra-group transaction documentation files for related parties in accordance with OECD guidelines and the Income Tax Rules:
- Master File
- Local File
- Summarized Table of Transfer Pricing Information
Documentation of intra-group transactions
Preparation of intra-group transaction documentation files for related parties in accordance with OECD guidelines and the Income Tax Rules:
- Master File
- Local File
- Summarized Table of Transfer Pricing Information
Documentation of intra-group transactions
Preparation of intra-group transaction documentation files for related parties in accordance with OECD guidelines and the Income Tax Rules:
- Master File
- Local File
- Summarized Table of Transfer Pricing Information
Documentation of intra-group transactions
Preparation of intra-group transaction documentation files for related parties in accordance with OECD guidelines and the Income Tax Rules:
- Master File
- Local File
- Summarized Table of Transfer Pricing Information
Documentation of intra-group transactions
Preparation of intra-group transaction documentation files for related parties in accordance with OECD guidelines and the Income Tax Rules:
- Master File
- Local File
- Summarized Table of Transfer Pricing Information
Documentation of intra-group transactions
Preparation of intra-group transaction documentation files for related parties in accordance with OECD guidelines and the Income Tax Rules:
- Master File
- Local File
- Summarized Table of Transfer Pricing Information