Services

Transfer Pricing Services

     

Plan: Provide Clarity

 (Gain strategic alignment with your international transfer pricing objectives)

Develop an international transfer pricing approach: A global approach that is right for your company requires a clear view across a complex set of variables. Together, we’ll navigate the world of transfer pricing by reviewing your current data and economic landscape to create clarity. We will empower you to design a pathway to action.

 

Transfer Pricing Planning

To achieve the goal of core competitiveness improvement, reasonable resource allocation and profit maximization,  you should coordinate various operating activities of your entities. We will assist in the modelling of related party transaction arrangements and corresponding pricing policies. We will also provide professional advice on the functions, risks and assets profile of each entity, and suggest the contribution of all parties within your group from the DEMPE perspective.

Streamline: Transform Operations

(Transform your international transfer pricing operations)

Automate your transfer pricing documentation through a pragmatic approach to transfer pricing technology: One of the biggest challenges in transfer pricing is ensuring that your business model and transfer pricing policy translates into a simple intercompany agreement that is accurately reflected in your financial statements and statutory returns. Often, the data you need for transfer pricing is not "tax sensitized" and is scattered across disparate IT systems and databases. We'll turn these challenges into an opportunity to create a pragmatic, user-friendly solution. We'll work with you to design and streamline your processes―and then automate them using an appropriate technology solution that fits your long term IT vision. As a result, you'll transform your tax department, and go from simply being compliant to being in control.

 

OTP

You have increasingly higher requirements on the timeliness, data accuracy and data availability in controlled transaction management. The operational transfer pricing (OTP) solution will connect with the ERP system of your group to realize two-way interaction with the original ERP data. 

Based on the transfer pricing regulations and requirements, we can capture the data from ERP system, and give feedbacks to the ERP system with our analysis results, for the easiness of corporate decision-making and implementation. In the meanwhile, the OTP solution can also take customs requirements into consideration, so as to realize the informatization and intelligence of the comprehensive transfer pricing management.

 

Transfer Pricing Risk Assessment and Health Check

Both the China transfer pricing regulations and the OECD transfer pricing guidelines have introduced asset valuation methods as optional methods in identification of the arm's length prices for specific intercompany transactions. We noted that China tax authorities have been concerned about such transactions and have stepped up efforts of investigations into such transactions. We provide tax valuation consulting services. We are committed to helping you successfully plan and execute transactions through our expertise in valuation.

 

Transfer Pricing Valuation

Both the China transfer pricing regulations and the OECD transfer pricing guidelines have introduced asset valuation methods as optional methods in identification of the arm's length prices for specific intercompany transactions. We noted that China tax authorities have been concerned about such transactions and have stepped up efforts of investigations into such transactions. We provide tax valuation consulting services. We are committed to helping you successfully plan and execute transactions through our expertise in valuation.

 

Business Model Optimization (BMO)

Continued advances in technology, a thirst for best practices, and potential changes in legislation are remarkable features of the current global economic environment. In this context, it is imperative to assess the global business model of your group. Business model optimization (BMO) strives to balance the business operation and tax compliance, and integrates the two into the business model. BMO helps to ensure that tax planning does not have a negative impact on your net profit margins, and on the contrary, the business model does not damage the part or all of the value created by tax planning. We provide tailor-made quality tax and business model optimization services, focusing on assisting multinational groups to integrate your operations and tax planning in an scalable and growing manner, and helping the management make more effective decisions to improve your profit margins.

Manage: Standerdize Processes

(Standardize your tax governance processes and policy)

The international transfer pricing governance lifecycle: Having a globally consistent view of your tax data is a continuous challenge for leaders of multinational companies. We leverage best practices to help you develop an effective framework that will increase the global consistency of your transfer pricing data across all of your operations.

 

Transfer Pricing Documentation

Preparation of local file: Following the relevant requirements of Announcement No. 42, local file mainly disclose the details of related party transactions. Specific services that we can provide include: related party relationship and related party transaction disclosure, industry analysis, functional risk analysis, location specific factor analysis, comparability analysis, special factor analysis (if necessary), etc., in order to form transfer pricing local file, and to indicate the consistency with arm's length principle and transefer pricing regulatory requirements;

Preparation of the master file: The master file mainly discloses the sketch of overall global business of the group to which the ultimate parent company belongs, including the organizational structure, the business operations, intangible assets, financing activities, and financial and tax status;

Preparation of special matter file: Special matter files include special matter files for cost-sharing agreements and special matter files for thin capitalisation. Failure to prepare a thin capitalization report as required will result in the related party interest expenses not being deductible before tax.

 

Country-by Country report  (CbCr) Review

We are pleased to see that as Chinese companies have boomed, more and more have reached the threshold of preparing country-by-country ("CBC") report. Considering the different requirements of local regulations globally, we are glad to help prepare the updated information matrix of the requirments of CBC reort notification and assist to prepare or review CBC report, and help prepare CBC report notification to ensure compliance with local transfer pricing regulations.

Resolve: Be Confident

(Confidently manage interactions with the global tax authorities)

Lower your international transfer pricing risk profile: We are in a time of unprecedented change in the global tax landscape, resulting in continuous uncertainty—compounded by increased scrutiny from revenue authorities and the media. This intensifies the spotlight on tax leaders. Our transfer pricing controversy practice is here to help.

 

Advanced Pricing Arrangement ("APA")

Transfer pricing poses a number of challenges to your tax, legal, and operations -- can management devote sufficient time costs and efforts to handle a transefer pricing audit? The uncertainty means business risks that you cannot afford. By actively negotiating with one or more tax authorities, you can reach an agreement in advance on the transfer pricing implementation and enhance certainty. We have been engaged in advanced pricing arrangements for many years. As a result, we have extensive experience all over the world. We are able to help you plan ahead and more proactively manage major transfer pricing issues such as double taxation risk.

 

Transfer Pricing Dispute Settlement

Any errors in responding to inquiries and interviews by competent tax authorities usually have a significant negative impact on the process and outcome of transfer pricing audit. To achieve more with less, it is imerative to introduce a global team with successful experience in all aspects of the transefer pricing audit as soon as possible. The team should be familiar with dealing with adjustments proposed by tax officials on the spot,  and be adept at taking advantages of advanced pricing arrangements, administrative reconsideration, administrative litigation, and mutual agreement procedure/corresponding adjustments ("MAP/CA"). We adopt an integrated approach to effectively resolve transfer pricing disputes in the MAP/CA process. Our team includes transfer pricing MAP/CA experts from both countries involved and professionals who are well versed in the specific requirements of the respective countries. Thus our team can provide professional advice on indirect taxes, local or state/provincial taxes, international taxes and the calculation of interest on back taxes that affect adjustment results.


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