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TRANSFER PRICING SERVICES FOR GLOBAL ENTERPRISES
Navigate the complexities of intercompany pricing with confidence. Expert transfer pricing documentation, compliance, and strategic advisory services aligned with OECD guidelines and local regulations worldwide
What is Transfer Pricing?
Transfer pricing refers to the rules and methods for pricing transactions between related entities within a multinational enterprise operating across different tax jurisdictions
Arm's Length Principle
Intercompany transactions must be priced as if they occurred between unrelated parties under similar circumstances, ensuring fair market value and preventing profit shifting.
Global Regulatory Framework
OECD Transfer Pricing Guidelines, BEPS Actions 8-10 and 13, and country-specific regulations govern how multinational enterprises document and justify intercompany pricing.
Documentation Requirements
Master File, Local File, and Country-by-Country Reporting (CbCR) are required to demonstrate compliance with transfer pricing regulations and substantiate arm's length pricing.
Transfer Pricing Compliance Process
Systematic approach to developing robust transfer pricing documentation and ensuring regulatory compliance across jurisdictions
Functional & Risk Analysis
Conduct comprehensive analysis of functions performed, assets employed, and risks assumed by each entity in intercompany transactions. Map value chain and identify key value drivers.
Comparability Analysis
Identify and analyze comparable uncontrolled transactions or companies. Conduct database searches and apply comparability adjustments to establish arm's length range.
Transfer Pricing Method Selection
Select most appropriate transfer pricing method: CUP, Resale Price, Cost Plus, TNMM, or Profit Split. Justify method selection based on facts and circumstances.
Documentation Preparation
Prepare comprehensive Master File, Local Files for relevant jurisdictions, and Country-by-Country Report. Ensure alignment with OECD BEPS Action 13 requirements.
Interquartile Range Testing
Test actual results against arm's length range. Identify potential adjustments required to maintain compliance and minimize audit risk.
Annual Update & Monitoring
Update transfer pricing documentation annually, monitor regulatory changes, assess new transactions, and maintain contemporaneous documentation for audit defense.
Why Transfer Pricing Compliance Matters
Critical importance of proper transfer pricing for multinational operations
Key Drivers
Regulatory Compliance
- Mandatory documentation requirements in 100+ countries worldwide
- Severe penalties for non-compliance ranging from 10% to 200% of tax adjustment
- Increasing scrutiny from tax authorities globally through BEPS implementation
Audit Risk Mitigation
- Transfer pricing is the #1 audit focus area for tax authorities worldwide
- Proper documentation provides audit defense and reduces adjustment risk
- Contemporaneous documentation can shift burden of proof to tax authorities
Avoid Double Taxation
- Prevents taxation of the same income in multiple jurisdictions
- Reduces risk of transfer pricing adjustments and correlative relief challenges
- Enables access to Mutual Agreement Procedures (MAP) and APAs
Tax Certainty & Planning
- Advance Pricing Agreements (APAs) provide multi-year tax certainty
- Strategic transfer pricing can optimize global effective tax rate
- Supports mergers, acquisitions, and business restructuring initiatives
Operational Efficiency
- Well-designed transfer pricing policies streamline intercompany transactions
- Supports performance measurement and management reporting
- Aligns tax strategy with business operations and value creation
Reputation & Stakeholder Confidence
- Demonstrates commitment to responsible tax practices and transparency
- Supports ESG initiatives and tax governance frameworks
- Builds trust with investors, regulators, and public stakeholders
Transfer Pricing Methods Comparison
CUP (Comparable Uncontrolled Price)
Resale Price Method
Cost Plus Method
TNMM (Transactional Net Margin Method)
Profit Split Method
| Method Type | Traditional Transaction Methods | Transactional Profit Methods | CUP Method | Profit Split Method |
|---|---|---|---|---|
| CUP (Comparable Uncontrolled Price) | Most direct method - compares price charged | Best when highly comparable transactions available | Preferred by tax authorities when applicable | Requires high degree of comparability |
| Resale Price Method | Appropriate for distributors - gross margin on resale | Suitable for marketing and distribution activities | Common for routine distribution functions | Less sensitive to product differences |
| Cost Plus Method | Appropriate for manufacturers/service providers | Markup on costs compared to comparable companies | Suitable for contract manufacturing | Common for routine services and manufacturing |
| TNMM (Transactional Net Margin Method) | Most commonly used method globally | Net profit margin compared to comparable companies | Flexible and less sensitive to minor differences | Widely accepted by tax authorities |
| Profit Split Method | Splits combined profits based on value contribution | Appropriate for highly integrated operations | Suitable for unique intangibles | Increasingly important for digital economy |
Our Comprehensive Transfer Pricing Services
End-to-end transfer pricing solutions from documentation to dispute resolution
TP Documentation
Master File, Local File, and Country-by-Country Reporting preparation compliant with OECD BEPS Action 13 and local regulations across 100+ countries.
Benchmarking Studies
Comprehensive economic analyses using proprietary databases to establish arm's length ranges and support transfer pricing positions with robust comparables.
TP Policy Design
Strategic development of transfer pricing policies aligned with business operations, value creation, and tax optimization objectives while ensuring regulatory compliance.
Advance Pricing Agreements
Negotiate unilateral, bilateral, and multilateral APAs with tax authorities to secure multi-year pricing certainty and eliminate audit risk.
Audit Defense & Controversy
Expert support during transfer pricing audits, preparation of audit response documentation, and representation in competent authority proceedings.
Business Restructuring
Transfer pricing analysis and documentation for reorganizations, acquisitions, divestitures, and supply chain realignments including IP migration and exit taxation.
Intangible Property Valuation
Valuation of patents, trademarks, trade secrets, and other intangibles for transfer pricing, cost sharing arrangements, and IP licensing transactions.
Permanent Establishment Risk
Assess and mitigate PE risk arising from cross-border services, digital presence, and commissionaire arrangements in light of BEPS Actions 7 and MLI.
TP Training & Advisory
In-house training programs, process optimization, technology implementation, and ongoing strategic advisory to build internal transfer pricing capabilities.
Related Cross-Border Compliance Services
Strengthen your international tax position with our comprehensive suite of cross-border compliance and advisory services
International Tax Planning
Strategic tax planning for multinational operations including entity structuring, treaty optimization, and global tax efficiency initiatives.
BEPS Compliance
Comprehensive BEPS implementation support including Action Plan compliance, MLI adoption, digital services taxation, and Pillar One/Two readiness.
Global Mobility Services
Cross-border employment tax planning, social security optimization, expatriate tax compliance, and permanent establishment risk assessment.
Customs Valuation & Compliance
Customs valuation services, transfer pricing and customs alignment, duty optimization, and trade compliance advisory.
Tax Treaty Services
Tax treaty analysis, withholding tax optimization, treaty benefit eligibility, and Mutual Agreement Procedure (MAP) support.
Business Valuation Services
Independent business and intangible asset valuations for transfer pricing, M&A transactions, financial reporting, and tax compliance.