Transfer Pricing Advisory & Documentation
What is Transfer Pricing about and how does it affect you
Due to increased tax authority scrutiny around the world, transfer pricing has become one of the riskiest areas for multinational corporations from both a compliance and tax planning perspective. Amazon, AOL, Adobe, Hewlett-Packard, Microsoft, and other multinationals have all made headlines in recent years because of transfer-pricing disputes over potential adjustments to income ranging from tens of millions to upward of a billion dollars. However, if you think transfer pricing affects only big companies, think again. Size is immaterial. The only condition that triggers transfer pricing is the existence of multiple facilities in more than one taxing jurisdiction.
We helped advise how companies can best manage their transfer pricing life cycle. The life cycle consists of four phases, which include planning, implementation, documentation and monitoring. While most companies have focused their efforts on the first three phases, the changing tax landscape results in companies seeking to manage new pressures, such as the increased data collection and information sharing among tax authorities, through the active monitoring of their transfer pricing positions. It is important that companies develop a clearly defined process to manage and mitigate their transfer pricing risks.
Transfer Pricing documentation and bench marking analysis
Transfer pricing documentation and bench marking analysis are key when defending transfer pricing risks from tax authorities. However, the reality is that the theory and practice of preparing documentation and bench marking analysis are very different, hence the importance of practical insights.
We helped companies design and document appropriate transfer pricing strategies and approaches for their related party transactions.
Our experts possess the Masters of International Taxation (New South Wales), Accredited Tax Advisor (Income Tax & GST) from SIATP, Chartered Tax Adviser (Australia), Fellow of the Taxation Institute of Hong Kong and member of the Tax Executive Institute (USA). We assisted clients in India, China, Australia, Malaysia, Thailand, Philippines, Vietnam, Indonesia and Singapore in defending their transfer pricing arrangements with tax authorities and advised on complex transfer pricing issues with MNE (Multi-National Enterprises) and SGX listed companies. We have extensive experience in the manufacturing, high technology, hospitality, as well as healthcare industries. In addition to transfer pricing, we are also skilled in IP Section 19B valuation work and completed the Certified Patent Valuation Analyst course organised by IPOS.