BEPS & Transfer Pricing
Transfer pricing is often one of those tasks that slips into the ‘we know it needs to be done, but it isn’t a top priority right now’.
A number of jurisdictions now require you to certify that transfer pricing documentation is in place when the tax returns are filed.
This results in either rushing at the last minute to get the documentation done, often enlisting expensive Big Four resource to complete work that could have been done much cheaper in house, or ticking the box and hoping you have time to get it done in the near future and face possible penalties if it isn't completed.
Having had over 15 years of experience with transfer pricing protocols and being familiar with the new BEPS requirements, we can take this off your to-do list by liaising with your tax advisors and internal teams to:
- Identify the appropriate transfer pricing methodology to adopt for different routes to market/ jurisdictions
- Identify new material related party relationships to be considered
- Update functional analyses and benchmarking after interviewing relevant staff
- Create Master and Local files as required by OECD BEPS rules
- Update existing documentation where required
- Assist with crafting reseller and management services agreements with subsidiaries
- Calculate any necessary end of year transfer pricing adjustments