We will assist in reorganizing and restructuring intercompany transactions according to acknowledged and legally accepted international transfer pricing rules. We will provide our clients with suitable intra-group agreements, transfer pricing documentation (including a master file and local files) prepared in accordance with local requirements and appropriate benchmarking studies to include third-party-comparisons for intercompany pricing. All these services can be provided at very competitive rates.
What should be done?
1 – Fixing transfer pricing mistakes for past years (as far as still possible) by
- Implementing intercompany pricing where required
- Revisiting the form and content of intercompany agreements
- Identifying gaps in existing documentation and taking appropriate steps to fill same.
2 – Implement an appropriate transfer pricing system by
- Determining the most suitable transfer pricing methods for intra-group transactions
- Providing suitable intra-group agreements for intra-group transactions
- Providing the required (minimum) additional transfer pricing documentation according to the rules of the countries in which the group operates. Requirements differ by country as follows:
- short memos describing the business structure and transfer pricing methods applied (plus necessary intra-group agreements), where nothing else is needed
- ‘local files’ for companies of the group in cases where documentation for some companies of the group is mandatory (plus necessary intra-group agreements),
- ‘master files’ giving information on the structure of the group, its business and intra-group transactions as well as ‘local files’ for companies of the group in cases where such
documentation is mandatory (plus necessary intra-group-agreements),
- ‘country-by-country-reporting’ where necessary.
- arranging for benchmarking studies’ (by experienced and competitive suppliers) demonstrating the adequateness of the group’s transfer prices by third-party-comparisons
3 – Keeping the transfer pricing system up-to-date in the future by
- Adjusting pricing, agreements, and documentation in light of changes in the business and structure of the group
- Adjusting pricing, agreements, and documentation as a consequence of changes in legal requirements
How will it be done?
- As much as necessary to comply with the rules (to avoid unpleasant discussions with auditors, taxmen, higher taxes and fines)
- As little as necessary (to avoid unnecessary internal rules, procedures, documents, and data as far as possible)