Transfer pricing refers to the rules and methods for pricing transactions and transfers within and between enterprises under common ownership or control. Because of the potential for cross-border controlled transactions to distort taxable income, tax authorities in many countries can adjust intragroup transfer prices that differ from what would have been charged by unrelated enterprises dealing at arm’s length. Extensive databases and knowledge with regard to transactions are necessary to be able to provide a taxpayer with the know-how which can substantiate his intragroup pricing policy. We will be able to advice on the most efficient way group transactions can be structured and advice on what transfer pricing consequences will result from this. We also can assist you in obtaining the right transfer pricing study for your operations and an advance pricing agreement (APA). An APA is an ahead-of-time agreement between a taxpayer and a tax authority on an appropriate transfer pricing methodology for a set of intragroup transactions.
International tax and finance specialists