Transfer Pricing

Multinational organisations are operating in an environment of unprecedented complexity. The rising volume and variety of intercompany transactions in the midst of a continually evolving transfer pricing regulatory landscape, accompanied by increased enforcement activities worldwide, have made transfer pricing a leading risk management issue for global businesses. Deloitte assists in planning, streamlining, managing, and solving complex transfer pricing issues to mitigate transfer pricing risk and aligning it with the client’s global business operations and objectives. Services include strategic advice on the remuneration model that aligns with value chains, providing solution-based economic analysis, and documenting positions to support regulatory requirements, resolving disputes and gaining tax certainty.

TP Consulting and advisory

  • Support and advice on BEPS readiness and implementation
  • BEPS Contract Analysis
  • Advice on alternative business models and implementation support
  • Alignment of the remuneration model with value chain and TP risk assessment
  • TP analysis of financial transactions
  • TP analysis and advice on complex transactions involving intangibles

TP Compliance and management

  • Operational transfer pricing
  • Advise on the applicability of master file and country-by-country (CbC) reporting requirements
  • Global/regional documentation – preparation of the master file, CbC report, and local file
  • Regional/country comparable studies

Controversy Management and Resolution

  • Dispute prevention – Advance Pricing agreement
  • Dispute resolution – domestic litigation and mutual agreement procedure
  • Safe harbour applications and audit proceedings