Transfer Pricing
Transfer Pricing Beyond Compliance—Designed for Value and Defensibility
Transfer pricing has become a corporate boardroom priority for corporates globally. Its evolution from a compliance function to a business planning function has necessitated proactive and continuous evaluation of intra-group transactions to assess transfer pricing risks arising from such transactions. As organisations expand their business through presence abroad, the attribution of profit commensurate with the functional and risk profile of group entities in various jurisdictions, while ensuring overall group tax efficiency, becomes critical.
Our role is to assist organisations in defining transfer pricing policies that are aligned with the value creation and designed to mitigate litigation.
Our key service offerings
- Transfer Pricing Documentation: Prepare and validate TP documentation and filings, benchmarking, functional & risk profiling, and Country-by-Country (CbC) & Master File support
- Global TP Policy & (Re)Structuring: Design a group-level transfer pricing framework that aligns with value drivers and business strategy, or assist in reviewing the existing framework
- Supply Chain & Process Review: Integrate tax into supply chain decisions — review logistics, procurement, intercompany services, and distribution models.
- Cross-Jurisdictional Applicability & Planning: Assess TP rules in multiple jurisdictions and structure transactions to optimize global tax positions.
- Advance Pricing Agreements & Safe Harbour: Support with unilateral/bilateral APAs, safe harbour applications, compliance monitoring.
- Dispute Resolution & Assessment Support: Represent clients before various tax authorities, handle TP assessments / audits and assistance in preparing submissions.
- Global documentation (including benchmarking): Assisting Groups in preparing global transfer pricing documentation
- Documentation for Intra Group Services: Assisting corporates in compiling documentation for various Intra Group services / management services
