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.