Transfer pricing

Transfer Pricing

Worldwide, tax authorities are increasingly focusing-in on inter-company transactions and the complexity of legislation and regulations across multiple jurisdictions makes transfer pricing one of the leading risk management issues for global businesses.

Deloitte Russia’s transfer pricing team are No. 1 in the region and ideally placed to help you plan your transfer pricing strategy and documentation, to assist you in concluding advance pricing agreements, or to assist you in any disputes that may arise.

Working with Deloitte specialists across the globe, we can fine tune your business model to balance the demands of your operations and international tax legislation and integrate them into your business model.

Transfer pricing planning and documentation

Our experts combine a thorough understanding of the local transfer pricing situation with many years of experience in mature jurisdictions to ensure that you get the very best advice and assistance. Our proprietary software rules out manual errors and provides quicker results, meaning that we can handle urgent requests for assistance.

So, whether you need advice on documentation or a fully planned transfer pricing solution complete with a full document package, our specialists are ready to help. 

Dispute avoidance: advance pricing agreements

Transfer pricing litigation is expensive, consumes management time and carries significant risk. Businesses with high volumes of controlled transactions or a limited number of high value transactions should consider the option of an advance pricing agreement with the tax authorities.

We can help you develop a pricing methodology, conduct negotiations and reach agreement with the authorities in advance, providing your business with important security. 

Dispute resolution

Should you be in dispute with the tax authorities, you will need the very best advice and assistance. Our aim is always to secure an agreement and avoid litigation but if a dispute reaches the courts, it is comforting to learn that our dispute resolution team have a success rate in excess of 90 percent.

Our team can help with pre-court settlement of tax disputes, providing legal support during tax audits, preparation of objections to tax audits and representation during discussions of tax audit materials with tax authorities. We provide representation in all types of proceedings, assisting you  to development a defense strategy, helping you implement measures preventing the collection of funds, preparing court documents and participation in court hearings.

Business model optimisation

Assessing a multinational’s global business model is no longer an optional exercise. There is a  continuous need to ensure that improvements in technology are adopted, that best practices and processes are implemented , and that businesses adapt to changes in the legislative environment. Business Model Optimisation (BMO) balances the demands of operations and tax law and integrates them into the business model. This helps ensure tax planning does not adversely affect the bottom line and that the business model does not surrender some or all of the value it creates.

We provide high quality, customized tax and BMO services that focus on helping multinationals integrate operational and tax planning in a scalable and sustainable way in order to enable you to make more effective decisions.

Operational Transfer Pricing

Corporate tax departments often come across inconsistent transfer pricing data from their business units and this can dramatically increase business complexity and the workload of your team, and potentially cause problems at quarter- or year-end.

If your business has significant intercompany transactions, inconsistent or unpredictable TP results that impose burdensome data sourcing requirements or make it difficult to forecast the effective tax rate, our specialists can work with your existing ERP system, offering new tools and processes to help your tax department overcome serious data and process issues.

Our approach is structured, platform independent and will provide you with the power to effectively manage your TP systems, providing maximum benefit to your business and minimising risks.

Getting your operational transfer pricing systems right, will allow you to gain control over your transfer pricing position and identify quick wins, opportunities, anomalies and trends, both for individual transactions and your wider TP operations.