Transfer Pricing
Transfer Pricing goes beyond compliance. Transfer Pricing is a strategic enabler aligning tax, operations, strategy and governance. In today’s environment of evolving tax rules and global supply chain realignment, we help businesses design, implement, and sustain transfer pricing models that are practical, defensible, and support long-term value creation.
We provide the following Transfer Pricing offerings:
Transfer Pricing Planning & Policy Design
- Transfer Pricing policies aligned with business objectives
- Structure intercompany transactions (goods, services, intangibles, financing)
- Profit allocation methodologies (TNMM, CUP, profit split, etc.) to align value creation with profit attribution
Compliance and Reporting
- Benchmarking for all types of intercompany transactions
- Preparation of Local File, Master File, Country-by-Country Reporting, Disclosure Forms
- Country-specific Transfer Pricing documentation
- Transfer Pricing health check
Financial Services Transfer Pricing
- Transfer Pricing for banking, insurance, asset management, and funds (family offices)
- Pricing of intra-group financing transactions (intragroup loans, cash pooling, treasury, derivative pricing)
Dispute and Controversy support
- Audit defence and controversy management
- Mutual Agreement Procedures
- Risk assessments and negotiations with tax authorities
Advanced Pricing Agreements
- Unilateral Advanced Pricing Agreements
- Bilateral Advanced Pricing Agreements
- Multilateral Advanced Pricing Agreements
Operational Transfer Pricing
- Implementation of Transfer Pricing policies into ERP and financial systems and automation
- Ongoing monitoring of intercompany margins
- Year-end adjustments and true-up processes
- Internal controls and governance frameworks
