Deloitte International Tax Source
Arm's Length Standard
The Link Between Transfer Pricing and Customs Valuation - 2015 Country Guide
Multinational organizations are operating in an environment of unprecedented complexity. The rising volume and variety of intercompany transactions and transfer pricing regulations, accompanied by increased enforcement activities worldwide have made transfer pricing a leading risk management issue for global businesses. The goal of Deloitte’s transfer pricing network is to help companies manage risks by aligning practical transfer pricing solutions with their overall global business operations and objectives, assist with strategic documentation to support their transfer pricing practices, and resolve disputes efficiently. Deloitte has a well-earned reputation for quality and delivering results.
Transfer Pricing Planning and Documentation
Deloitte's transfer pricing professionals assist taxpayers with home country and foreign documentation requirements by preparing transfer pricing documentation reports that analyze the arm’s length nature of their intercompany prices. We can also assist multinationals with multiple foreign affiliates to prepare global documentation satisfying all of their documentation requirements in an efficient and consistent basis.
Dispute Avoidance: Advance Pricing Agreements (APAs)
Deloitte's transfer pricing professionals assist clients with all aspects of defending their transfer prices before the tax authorities and with local audit teams. If an audit results in a transfer pricing adjustment, Deloitte helps obtain double tax relief through the tax treaty competent authority process. Deloitte also helps clients negotiate Advance Pricing Agreements (APAs) to obtain prospective transfer pricing certainty.
Dispute Resolution: Examination Defense and Mutual Agreement Procedure/Competent Authority (MAP/CA)
Deloitte works with clients to explore strategic opportunities to enhance global tax and treasury planning, by aligning the relationship between the taxpayer’s value drivers and income/cost streams to improve their effective tax rate (ETF). This can include supply chain and intellectual property strategies and global charges. Deloitte's services help integrate operational and tax planning in a way that allows clients to treat tax as another cost of doing business making strategic decisions on an after tax basis.
Business Model Optimization
In light of today’s dynamic global economic environment and the potential for legislative changes, assessing a multinational’s global business model may no longer be an optional exercise. Deloitte’s Business Model Optimization (BMO) team provides high quality, customized tax and business model transformation services. With its focus on helping multinationals integrate their operational and tax planning in a scalable and sustainable way, BMO aims to enable business leaders to make more effective decisions on an after-tax basis. BMO is an approach for creating value through business transformation.