DESIGNING AND IMPLEMENTING A NEW TRANSFER PRICING MODEL
For an international group operating in a modern business environment, the key operational areas, the distinctive features of business, and the geographical coverage can change, sometimes even quite fast. This puts the internal operational and transfer pricing model to the test.
We help our customers grow, go international, and succeed by ensuring that all mandatory, transfer pricing related obligations are fulfilled in an appropriate manner. In our efficient TP|SWOT, or when more extensive changes are involved, our BMO (Business Model Optimization) engagements, we carefully study the context, interview the key persons, and take into account the latest regulatory changes and expected future scenarios to form a well-argued recommendation of an internal operational model that will minimize the risks and maximize the benefits – one that is best suited to the current situation, light to administer, and tax efficient.
Once the planning stage has been completed, we assist in putting the selected model into practice in daily operations (key practices, processes, and controls), in communications towards key interest groups (internal trainings, preliminary discussions, and agreement procedures with tax officials), in documentation (internal instructions and transfer pricing documentation), and, when required, in defense (tax audits and corresponding adjustment procedures).
As means of implementation, you can choose between a turnkey solution, or support targeted at certain core areas, depending on the required actions, variables, and available internal resources.
To guarantee maintenance and functionality for the model, we recommend our innovative TP|BackOffice service concept. Under this concept, we act as your trusted partner in all transfer pricing related matters and assume overall responsibility for the agreed tasks in a cost efficient manner.
DRAFTING AND UPDATING GROUP-LEVEL TRANSFER PRICING DOCUMENTATION
Transfer pricing documentation is a written account of cross-border business transactions between companies or permanent places of business that belong to the same multinational group. Even though the threshold limits for the documentation obligation vary between countries, the requirement to adhere to the arm’s length principle is applied to all companies who engage or plan to engage in international business.
The aim of transfer pricing documentation is to discover key business factors between the group companies and to prove that the pricing and terms terms applied to the intra-group transactions comply with the arm’s length principle.
We prepare a group-level transfer pricing documentation (Master File and Local File) that complies with the international and local requirements. We also help with maintaining and updating the documentation on an annual basis and, if necessary, defend it in potential dispute situations. We strive to do all this as efficiently as possible, drawing on our practical experience accumulated over the years and on our innovative approach.
To ensure appropriate maintenance of the prepared transfer pricing documentation, we recommend our innovative TP|BackOffice service concept. Under this concept, we act as your trusted partner in all transfer pricing related matters and assume overall responsibility for the agreed tasks in a cost efficient manner.
ARM’S LENGTH ANALYSES AND DATABASE STUDIES
For cross-border intra-group business transactions, ensuring compliance with the arm’s length principle requires validation based on independent comparable data and benchmarking studies.
We have access to all the key databases utilized in transfer pricing (such as BvD Orbis, RoyaltyStat, Bloomberg), and possess the skills to put them to efficient use. All the analyses we prepare are made in-house by our specialized team, utilizing our proprietary approaches honed to perfection over the years. The analyses and results can be utilized to support both the (advance) price setting and the (subsequent) validation of the arm’s length compliance.
In addition to individual, one-off analyses, we also offer a unique Benchmarking-as-a-Service (BaaS) concept under which we provide continuous and cost-effective maintenance service for the benchmarking studies prepared for documentation and validation purposes.
DELIVERY AND VALUE CHAIN ANALYSIS & OPTIMIZATION
Transfer pricing ultimately concerns analyzing contributions made by different group companies in relation to product or service specific, group-level delivery and value chains. Thus, working methods and analysis frameworks developed for arm’s length validation are especially suited for delivery and value chain analysis, as well as for broader business optimization purposes.
With the help of these analyses, we enable gaining deep understanding regarding the central aspects of efficiency and added value in business. Consequently, we can identify development and optimization targets and assess how they will possibly be affected by various alternative actions.
In engagements concerning delivery and value chains, we utilize not only our own tools but also market-leading digital solutions that enable even deeper analyses, particularly from the point of view of financial data utilization. To learn more about the digital solutions in our portfolio, please visit here.
ADVANCE PROCEDURES, LITIGATION, AND DISPUTE RESOLUTION
Although the guidelines regarding transfer pricing and the arm’s length principle are governed on international level, their practical application is always based on national laws and interpretations. That is why there is always a certain amount of uncertainty involved in the taxation of a group engaged in cross-border business operations.
We help our customers remove some of that uncertainty by versatile utilization of different advance procedures including – in addition to proactive communication and traditional preliminary rulings – pre-emptive discussions (both domestic and Cross-Border Dialogue) and Advance Pricing Agreements (APA). When required, we assist in national appeal and litigation processes where we aim to bring together our juridical and financial know-how to achieve end results that are acceptable for the customer.
Once the appeal process is over, we continue to ensure that – to avoid double taxation – the required corresponding adjustments are carried out either via a mutual agreement procedure (MAP) or via arbitration.
For proactive risk management and to guarantee maximum process efficiency in managing tax-related disputes arising in different countries, we recommend our innovative TP|BackOffice service concept. Under this concept, we act as your trusted partner in all transfer pricing related matters and assume overall responsibility for the agreed tasks in a cost efficient manner.
OUTSOURCING OF TRANSFER PRICING AS A SERVICE (TP|BACKOFFICE)
Over the years, we have noticed that transfer pricing issues can, at worst, delay the daily business operations of an internationalizing group. In a worst-case scenario, these can even hinder growth. However, few companies have the resources, or even the need, to hire someone to specifically tackle these difficult issues as a full-time job.
Based on the above, we have developed our unique TP|BackOffice service concept that involves offering our customers a whole team of seasoned professionals – with just the right scope, covering all the key operating countries of the group. The underlying idea is to replace separate one-off engagements with continuous and close cooperation. This means maximized efficiency and synergy benefits in supporting the daily pricing and planning processes and in maintaining an appropriate level of compliance.
The unique service concept is based on a monthly invoicing arrangement, thus ensuring full predictability and enabling us to become a trusted partner for our customers: one-stop-shop service provider and a trusted advisor. An outsourced, always-available expert resource that will provide help and support with low contact threshold and in relation to all transfer pricing issues arising in connection with daily business operations around the globe.
In addition to transfer pricing, the tailored service concept can cover also our other professional service areas (law and tax services, financial advisory). Via our extensive partnership network we can ensure that whenever required, appropriate local know-how will be available in all key operating regions of the multinational group.