Transfer Pricing (TP) Services

Transfer pricing (TP) is a vital topic as countries continue their search for international consensus on what is considered the “fair share” of tax. TP issues present enormous uncertainty to businesses, as different jurisdictions likely hold a different perspective based on their own economic and market circumstances. Properly ring-fencing this risk is therefore a high priority agenda item for management of companies that engage in related party transactions.

How we can help

Our team of TP experts is well placed to support you across a wide spectrum of TP matters:

Design and implementation

• Tailor made TP policy design.
• Review of processes and procedures from a tax internal control perspective.
• Assistance in operational roll out of new TP policies.
• Assistance in ERP (enterprise resource planning) or other in-house technology projects.
• Advice on inter-company contracts and agreements.

Controversy management

• TP audit readiness check (mock audit).
• Defence strategy compilation.
• Tax provision / accounting reserve assessment.
• Assistance in correspondences corresponding with tax authorities.
• Co-attendance of field audit meetings.
• Objections and appeals to TP adjustments.
• Application of MAP (mutual agreement procedure).
• Application of unilateral and bi-multi-lateral APAs (advance pricing arrangements).

Compliance

• Industry/market specific economic analysis (benchmarking) to substantiate your TP positions.
• Review and prepare related party disclosure forms in tax returns.
• Preparation of compliance documentation (for transactions exceeding mandatory thresholds).
• Country by country reporting notifications and filing.

Who Needs Tax Services?

• Corporations, charities, sole proprietorships, partnerships, expatriate employees, high-net-worth individuals, trusts and estates. All legal entities can benefit from tax services in terms of assurance of compliance with the relevant laws and, where possible, reduction in overall tax costs.