Compilation of Compliance Documentation

Action 13 released by the Organisation for Economic Co-operation and Development (OECD) in October 2015 as part of the OCED’s Base Erosion and Profit Shifting (BEPS) Action Plan, prescribes a three-tiered approach to Transfer Pricing documentation, comprising:

CbC Report

a Country-by-Country Report (CbC report) that provides information relevant for a high-level risk assessment in relation to each tax jurisdiction in which an MNE group operates;

Master File

A master file with information regarding a multinational enterprise’s (MNE group) global business operations and transfer pricing policies;

Local File

A local file with detailed information relating to transfer pricing transactions and policies in a specific tax jurisdiction.

We can compile your Transfer Pricing compliance documentation, using information obtained from you, such as your Annual Financial statements, website information, annual report, information obtained from functional analysis questionnaires and interviews, relevant agreements, etc.

We also offer the service of reviewing your current or prior Transfer Pricing documentation to assess your level of compliance with relevant guidance and legislation, providing recommendations to you with the intention of assisting you in minimising your risk of any Transfer Pricing adjustments by Revenue Authorities.

Unsure if you have an obligation to prepare and maintain Transfer Pricing documentation? Contact us to assist you in determining whether this obligation exists for you or not.

Compilation of Compliance Documentation

We can compile your Transfer Pricing compliance documentation, using information obtained from you, such as your Annual Financial statements.

Transfer Pricing Risk Assessment

Depending on your requirements, our assessment could focus on the Transfer Pricing risks of the local company, of all entities within a region, or of all entities within the multinational group as a whole.

Transfer Pricing Planning and Policy Setting

Using our sound technical expertise, we can assist you to identify the transactions which are subject to Transfer Pricing regulations.

Transfer Pricing Benchmarking Studies

With our access to the relevant benchmarking data, we can assist you in determining the arm’s length range of prices or margins for intercompany transactions.

Transfer Pricing Training and Training Materials

We can provide Transfer Pricing training and training materials, including practical, real-life examples and case studies, to suit your needs and ensure a transfer of knowledge.

Transfer Pricing Benchmarking Studies

With our access to the relevant benchmarking data, we can assist you in determining the arm’s length range of prices or margins for intercompany transactions involving goods, services

Assistance With Controversy and Dispute Resolution Related to Transfer Pricing

We can assist you to replace the fear and uncertainty in these engagements and disputes, with feelings of comfort and confidence.

Drafting of Relevant Intercompany Transfer Pricing Agreements

Guidance released by the Organisation for Economic Co-operation and Development (OECD) in October 2015 as part of the OCED’s Base Erosion and Profit Shifting (BEPS) Action Plan.