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Transfer Pricing Services
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 services 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.
Watch this video to view how Deloitte leverages a holistic, technology enabled approach to transfer pricing documentation.
Transfer Pricing Services
Deloitte's transfer pricing professionals assist taxpayers with home country and foreign documentation requirements by preparing transfer pricing documentation reports that analyze the arm’s length nature of their intercompany prices. We can also assist multinationals with multiple foreign affiliates to prepare global documentation satisfying all of their documentation requirements in an efficient and consistent basis.
Dispute Avoidance: Advance Pricing Agreements (APAs)
Deloitte's transfer pricing professionals assist clients with all aspects of defending their transfer prices before the tax authorities and with local audit teams. If an audit results in a transfer pricing adjustment, Deloitte helps obtain double tax relief through the tax treaty competent authority process. Deloitte also helps clients negotiate Advance Pricing Agreements (APAs) to obtain prospective transfer pricing certainty.
Dispute Resolution: Examination Defense and Mutual Agreement Procedure/Competent Authority (MAP/CA)
Deloitte works with clients to explore strategic opportunities to enhance global tax and treasury planning, by aligning the relationship between the taxpayer’s value drivers and income/cost streams to improve their effective tax rate (ETF). This can include supply chain and intellectual property strategies and global charges. Deloitte's services help integrate operational and tax planning in a way that allows clients to treat tax as another cost of doing business making strategic decisions on an after tax basis.
Value Chain Alignment
Value Chain Alignment (VCA) is the process of integrating a multinational company's operating model and global tax footprint, and ultimately balancing the demands of each, to create value. Deloitte's VCA team utilizes a broad-based approach focused on supply chain, IP, digital transformations, and business models that are commercially driven and provide both operational and financial benefits. We help business leaders enhance the tax efficiency of their company's operations through such means as internal business changes and restructurings, supply chain management, pre- and post-merger integration, and consolidation of business operations to reduce costs.