Transfer Pricing Consulting
Advance pricing agreements
Transfer pricing presents many tax, legal and operational challenges. To many taxpayers the magnitude of uncertainties – including the potential commitment of significant management time in the event of a transfer pricing examination – is not an acceptable business risk. APAs allow taxpayers to achieve greater certainty via advance agreements on their transfer pricing methods with one or more tax authorities.
Deloitte's experience with the APA process spans the development of the national programs and this historical knowledge and insight combined with more recent practical experience helps us help companies to manage their transfer pricing issues – particularly the risk of double taxation – on a prospective basis.
Business Model Optimisation
The alignment of a multinational company’s operating model and its global tax objectives is an important step in enhancing corporate profitability and shareholder value.
Business leaders often have to make tough choices when faced with competing priorities such as competitive pressure in the market and the internal desire for growth, regulatory constraints, and increased public scrutiny.
Currently these challenges are compounded by the uncertainty of a changing landscape. This is partially the result of the OECD’s Base Erosion Profit Shift (BEPS) project which has brought widespread regulatory and treaty changes across many jurisdictions and is part of an increased focus by tax authorities around the world on organisations operating across borders.
Increased public transparency and new compliance obligations will present fundamentally new challenges for multinationals operating across multiple jurisdictions.
Business Model Optimisation (BMO) is the process of integrating the operating model and global tax structures into the way a business operates. BMO is all about creating value through business transformation. Deloitte provides high quality, customised tax and BMO services that focus on helping multinationals integrate operational and tax requirements in a scalable and sustainable way in order to help business leaders to make effective decisions on an after-tax basis.
Deloitte delivers business model optimisation services using the BMO Insight methodology, a set of experience based approaches to developing solutions to a range of tax issues and opportunities.