Pro-tp will undertake a due diligence review of the historic and current business in order to detect past and present TP deficiencies. This review will form the basis of the provision of practical and flexible solutions.
Transfer pricing within the group may be inadequate for various reasons including:
- No intragroup pricing exists in circumstances whereby it is, in accordance with local tax laws, mandatory to charge connected parties for goods and/or services
- Intragroup pricing exists in circumstances whereby it is, in accordance with local tax laws, not mandatory to charge connected parties for goods and/or services
- Actual intragroup pricing is too high / too low
- The basis of intragroup pricing is unclear or not in line with applicable tax rules
- The necessary intra-group agreements do not exist or are insufficient
- Appropriate transfer pricing documentation doesn‘t exist or is insufficient / not in line with local requirements
Due diligence process
- Analyse the value chain, current TP policies and supporting documentation and determine, if it is in compliance with OECD standards, local regulatory standards etc. Document compliance with TP policies.
- Analyse the risks related to the TP policies of the business.
- Define new TP policies and documentation if necessary.