Transfer pricing

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Transfer pricing

Multinational organizations are operating in an environment of unprecedented complexity. The rising volume and variety of intercompany transactions and transfer pricing regulations, accompanied by increased enforcement activities worldwide have made transfer pricing a leading risk management issue for global businesses. The goal of Deloitte’s transfer pricing network is to help companies manage risks by aligning practical transfer pricing solutions with their overall global business operations and objectives, assist with strategic documentation to support their transfer pricing practices, and resolve disputes efficiently. Deloitte has a well-earned reputation for quality and delivering results.

Multinational businesses are expanding the volume of related-party transactions and continuously improving their supply chains. This coupled with increased tax authority collaboration across borders presents both risks and opportunities. Deloitte Turkey, provides practical solutions such as strategic approaches to transfer pricing documentation requirements, which help global businesses to achieve their operational and international tax objectives.

Transfer pricing documentation must demonstrate that the taxpayer’s policies are in line with regulatory requirements for appropriate methodologies and with the arm’s length standard. Deloitte Turkey  professionals are well-versed in the regulations of all countries involved in a documentation study and experienced in the collection and analysis of comparability data. Transfer pricing documentation will be the first line of defense in any transfer pricing audit.

By transfer pricing planning, our transfer pricing professionals can help businesses use transfer pricing as an opportunity– and not just as an added compliance burden. By integrating the right transfer pricing strategy with companies’ broader business objectives, our goal is to help generate tax savings that will significantly reduce companies’ global and local effective tax rate.

One of the most challenging complexities of transfer pricing is the application of the arm’s length standard. We apply creative thinking, practical knowledge, advanced analytical techniques and sophisticated technology in analyzing the arm’s length standard on companies’ behalf. With our benchmarking studies our goal is to align our transfer pricing solutions with both global and local business objectives.

Transfer pricing advisory and documentation

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. Advance pricing agreements (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.

Dispute avoidance: Advance pricing agreements

Often it is the actions and responses in the initial stages of a tax authority enquiries or interviews that affect the course or outcome of a transfer pricing examination. Accordingly effective and efficient explanation of a business transfer pricing policies include early involvement of an experienced global team that has  practical experience of all levels of the tax authority process, from proposed adjustments by field agents, through Advance Pricing Agreements, administrative appeals, litigation and the MAP process. Deloitte takes an integrated approach to resolving transfer pricing disputes in the MAP process. Our teams include transfer pricing MAP specialists from both countries in dispute teamed with professionals who specialize in local country requirements for indirect taxes, taxes imposed by local or state/provincial jurisdictions, international tax and interest calculations for late payment that invariably affect the outcome.

Dispute resolution: Audit defense and mutual agreement procedure