Transfer Pricing Services

Tax Controversy and Dispute Resolution

With more and more countries introducing formal transfer pricing documentation requirements and against a backdrop of increased transparency, transfer pricing audits and tax controversies are on the increase. As tax authorities become more sophisticated and data driven, and as their expectations of taxpayers grow, so audits are becoming ever more thorough.

This new environment therefore requires multinational corporations to take proactive, coordinated steps to understand their transfer pricing arrangements and documentation requirements, to have a clear view on how tax authority engagement should be managed and to maintain “audit ready” evidence to support the positions they take. Our Tax Controversy and Dispute Resolution experts are ready to help you:

• Manage your audits and examinations, both in Singapore and with regional counterparties. We can help you navigate the issues raised, identify the evidence required and attend the necessary meetings with the Tax Authorities to resolve matters.
• Devise an overall strategy for resolving disputes, including a consideration of the appropriate forum, be that domestic appeals or Mutual Agreement Proceedings. Where, as is often the case, the matters in dispute cover multiple jurisdictions, our teams can work with you to ensure a coordinated and consistent approach is adopted to reduce risk and expedite outcomes.
• Take a proactive stance by initiating unilateral or bilateral APAs.

Financial transactions

Our specialists help companies navigate the complexities of intercompany financing by delivering tailored assessments of thin capitalisation, debt pricing, cash pooling, hedging and intercompany guarantee arrangements.

With ever more focus by local and regional tax authorities on financial transactions it is important that transfer pricing policies are coordinated and aligned across jurisdictions. Our dedicated team of Financial Services and Financial Transactions specialists are here to help you design, implement, defend and document transfer pricing policies for Financial Transactions and Treasury activities. 

Transfer pricing implementation

A policy is only as good as its execution. It’s the last mile that makes all the difference to managing your transfer pricing risk. While the outcome of transfer pricing compliance is principally the responsibility of the tax function, execution of intercompany transactions often spreads across several other functions such as controllership, accounting, IT, legal, trade and customs.

A clear governance process with responsibilities understood across business functions forms the backbone of good TP execution. Recognising this TP execution is more than just a tax function’s responsibility, our team comprises experts not only in transfer pricing but also in customs and trade, indirect tax, accounting, management, IT and change consulting. Our team can help you:

• Review, set and embed the overall strategy, risk and governance framework for transfer pricing.
• Design or remediate cross functional processes for setting, monitoring and adjusting intercompany prices.
• Optimise the efficiency of price setting and controls processes, including support in evaluating and implementing technology and automation solutions.
• Manage the implementation of true ups with the tax and customs authorities.

Robust, affordable documentation

A key feature of the rapidly evolving tax landscape is the drive for increased transparency and reporting and the concomitant increase in taxpayer scrutiny and controversies. Transfer pricing documentation is therefore not only a compliance requirement in most markets, but also represents the first line of audit defence. Accordingly, best in class companies adopt documentation with more than just a compliance mindset and consider it as a central plank in their strategic tax risk management strategy.

Our experts can help you to assess your compliance and strategic needs holistically, and develop a ‘fit for purpose’ approach to managing your transfer pricing risks in a cost effective manner. Our work includes:

• Assisting in the preparation of all aspects of transfer pricing compliance documentation – Local Files, Master File, Regionally or Globally Coordinated Documentation, Related Party Transaction disclosures and country-by-country reporting.
• Gathering evidence in support of “need/benefit” tests for intercompany services.
• Preparing audit ready defence files.

Our services are delivered using a technology enabled approach with leading-edge tools to drive efficiency and improve quality through rich and granular data analysis and a coordinated workflow, document and data management system.