Transfer Pricing Services for the Financial Service Industry
The environment surrounding financial industry/transactions has become increasingly complex. As a result, transfer pricing audits in different countries have become more stringent. In particular, given that the Japanese tax authorities' knowledge and experience with respect to financial transactions have been accumulating each year, taxpayers should prepare for and address the tax authorities' transfer pricing enforcement.
Transfer Pricing Services for Various Financial Sectors
Our services for the banking sector include advice with respect to transfer prices for all types of banking intercompany transactions (origination, lending, trustee services, etc.) as well as income, cost, asset, and capital attributions associated with internal dealings between head offices and branch offices and between sister branches based on the Authorized OECD Approach (""AOA"") for attributing income to permanent establishments.
Our services for the securities sector include advice with respect to the transfer pricing for capital markets trading, investment banking advisory services, funds transfer pricing, and all types of middle and back office services. In particular we deal with remote booking and return on capital issues.
Our services for the insurance sector include advice with respect to intercompany reinsurance transactions, asset management, allocations of headquarter expenses, captive insurance. We also are involved in determining and supporting arm's length prices for internal dealings between head offices and branches and the attribution of investment assets based on the AOA.
Asset Management Sector
Our services for the asset management sector include advice with respect to management fees splits between related parties involved sales & marketing, portfolio management, client servicing; determination of pricing for research and other services; and allocation of headquarter expenses. We services asset managers in the traditional and alternative investment sectors.
For financial service and general corporate clients we provide services addressing the transfer pricing of intercompany loans, financial and performance guarantees, factoring, and cash pooling.