Transfer pricing reviews, encompassing functional, risk and benchmarking analysis. Pro-tp will review the current cross-border intragroup transactions to verify whether or not they comply with the tax rules of the affected countries.
Our services include the following:
- Review the legal ownership and geographical location of operations.
- Determine the drivers of profit, understand current markets, intercompany service arrangements etc
- Understand the functions performed by various divisions of the Group.
- Identify the most important business risks at group level.
- Understand what intangibles exist within the group, list and identify the intangibles relevant for TP purposes, understand what agreements are in place to use IP, understand the group policy on R&D, determine to what extent intangibles have been transferred or used by other connected persons.
If necessary undertake the following additional steps:
- Define and describe the controlled transaction.
- Describe the functions performed by the relevant party, the contribution to the overall value chain.
- Describe the risks borne by the tested party.
- Select the most appropriate TP method based on the analysis performed above.
- Select appropriate comparables.
- Apply the results of work undertaken to the facts of the relevant case.
- Update the transfer pricing report incorporating the items referred to above.
Feel free to contact us with any questions by filling in the form below. We could get you in touch with one of our partners.