Transfer Pricing

Although the global economy is seeing signs of recovery, there continue to be challenges ahead that need to be addressed within the changing transfer pricing landscape. On the one hand, the OECD is set to release the final draft of the revised transfer pricing guidelines and launch a new project on intangibles. On the other hand, several countries have adopted new / revised requirements for transfer pricing and are increasing their focus on dispute resolution.

The Indian landscape is also witnessing change, with safe harbour rules and advance pricing arrangements on the cards and MAP evolving as an alternate dispute resolution mechanism. To thrive through these challenging times, we offer MNCs valuable long-term strategies with a global perspective on how to meet these increased transfer pricing challenges.

If this is your situation:

  • You are interested in “best practices” for managing your worldwide transfer pricing policies and procedures
  • You need assistance in constructing effective cross-border strategies and managing global effective tax rates
  • You need to respond to transfer pricing audit / enquiries from tax authorities
  • You need expert advice on the transfer pricing implications of existing or proposed international transactions
  • You need to align your international transactions with your global transfer pricing policy or formulate a local transfer pricing policy
  • You need advice on transfer pricing documentation requirements in India or other jurisdictions
  • You need to know whether your internal controls over transfer pricing are sufficient and how they can be improved  


How we can help you

We will work with you to ensure that your organisation is adding sustainable value while
managing global risk, and together we will devise a successful strategy to take advantage of the evolving transfer pricing landscape. 

We provide leading edge tools and solutions relevant to your industry in the areas of:

  • Developing a coherent and defensible TP policy
  • Compliance and documentation management
  • Strategising and assisting in dealing with Global Dispute Resolution
  • Value Chain TransformationTM(VCT) 2 / Global Structure Alignment
  • Evaluating and addressing the implications of the proposed changes in regulations


 

1 Launched in 2000, the Global Tax Monitor is a multi-client independent survey conducted by the research agency TNS that examines the competitive position of the top firms in the tax advisory market - globally, regionally, nationally and on an industry basis. It provides a comprehensive measure of firm reputation, client service and brand health, gained currently from just over 3,000 telephone interviews annually with key decision makers (CFOs and Tax Directors) in 31 key markets worldwide. These results are based on the year-ending Q4 2009 figures.
 

2 VCT focuses on transforming the way a group’s business model and supply chain arrangements work, from overall strategy to customer delivery, and simultaneously achieving a lower worldwide effective tax rate for a group within an acceptable risk matrix.  The proposition is based on the international tax principle that profits follow functions, assets and risks. Some of the benefits groups achieve through VCT include alignment of tax with business operations, creation of synergies, reductions in complexity, reductions in operating costs, and gaining assistance with cash repatriation planning.