Transfer pricing
Multinational organisations are operating in an environment of unprecedented complexity. The rising volume and variety of intercompany transactions and transfer pricing regulations, accompanied by increased enforcement activities worldwide have made transfer pricing a leading risk management issue for global businesses.
Global transfer pricing rules often require taxpayers to explain the economic foundation and results of their intercompany transactions. Deloitte's teams are composed of economists and lawyers who review clients' internal data and leverage it with publicly available sources and original research to explain the economic foundation of underlying intercompany transactions. This includes reviewing risk allocations in intercompany arrangements within a meaningful industry analysis, deploying the methods and guidance provided in national tax rules and the OECD guidelines.
The goal of Deloitte's globally-managed transfer pricing network is to help companies reduce risks by aligning practical transfer pricing solutions with their overall global business operations and objectives, assist with strategic documentation to support their transfer pricing practices, and resolve disputes efficiently. Deloitte has a well-earned reputation for quality and delivering results. Our services include:
- Transfer pricing planning and documentation
- Dispute avoidance: Advance pricing agreements
- Dispute resolution: Examination defense and mutual agreement procedure/competent authority
- Business model optimisation
Transfer pricing planning and documentation
Deloitte’s transfer pricing professionals can assist taxpayers with their home country and foreign documentation requirements by preparing transfer pricing documentation reports that support the arm’s length nature of their intercompany prices. Deloitte can also assist multinationals with multiple foreign affiliates to prepare global documentation to satisfy all of their documentation requirements in an efficient and consistent basis.
Dispute avoidance: Advance pricing agreements (APAs)
The best way to obtain prospective transfer pricing certainty and avoid disputes is to conclude a unilateral domestic advance ruling or to negotiate a bi- or multilateral advance pricing agreement. Deloitte helps clients evaluate the need for such ruling or agreement and also assists them in their negotiations with the authorities in this respect.
Dispute resolution: Examination defense and mutual agreement procedure/competent authority (MAP/CA)
Deloitte's transfer pricing professionals assist clients with all aspects of defending their transfer prices before the tax authorities or with local audit teams. If an audit results in a transfer pricing adjustment that is deemed unfair, Deloitte assists taxpayers in seeking double taxation relief through the tax treaty processes with competent authority or through arbitration.
Business model optimization (BMO)
Deloitte works with clients to explore strategic opportunities to enhance global tax and treasury planning, by aligning the relationship between the taxpayer’s value drivers and income/cost streams to improve their effective tax rate (ETR). This can include supply chain strategies, intellectual property strategies and global charges. Deloitte's services help to integrate operational and tax planning in a way that allows clients to treat tax as another cost of doing business and make strategic decisions on an after tax basis.
Contacts
André Schaffers
Partner Tax
aschaffers@deloitte.com
Patrick Cauwenbergh
Partner Tax
pcauwenbergh@deloitte.com
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