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Transfer pricing

Overview

Transfer pricingCompanies operating around the world depend on the internal sharing of ideas, products and services to advance their global competitive position. When those ideas, products and services cross international borders, however, there’s a price to pay. Today, these organizations operate 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.

The goal of Deloitte member firms’ 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 

Multinational businesses are expanding the volume of related-party transactions and continuously improving supply chains. This coupled with increased tax authority collaboration across borders presents both risks and opportunities. Deloitte provides practical solutions such as strategically approaching transfer pricing documentation requirements, which enable global businesses to achieve operational and international tax planning objectives. For multi-country projects, Deloitte has a Global transfer pricing center, that includes economists, tax professionals and MBAs who have on-the-ground international transfer pricing experience and specialize in Europe, the Americas or the Asia Pacific region. This centralized, global approach facilitates uniformity of reporting and eliminates internal inconsistencies which can arise from multiple service providers, thereby making the process more effective and efficient and easier to successfully defend.

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Dispute avoidance: Advance pricing agreements (APAs) 

Transfer pricing presents many tax, legal and operational challenges. To many taxpayers the magnitude of uncertainties—including the potential commitment of management time to successfully defend a transfer pricing examination—is not an acceptable business risk. APAs allow taxpayers to proactively achieve greater certainty via advance agreements on their transfer pricing methods with one or more tax authorities. Deloitte’s experience with the APA process spans the entire history of all the national programs. Our historical knowledge of how to achieve successful results helps companies manage their transfer pricing issues—particularly the risk of double taxation—on a prospective basis.

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Dispute resolution: Examination defense and mutual agreement procedure/competent authority (MAP/CA) 

Missteps that affect the course or outcome of a transfer pricing examination often occur in responses to the initial tax authority enquiries and interviews. The most effective and efficient defenses include early involvement of an experienced global team that has successfully resolved examinations at all possible levels of the process, from proposed adjustments by field agents, through Advance Pricing Agreement, administrative appeals, litigation and the MPA/CA process. Deloitte takes an integrated approach to resolving transfer pricing disputes in the MAP/CA process. Our teams include transfer pricing MAP/CA specialists from both countries teamed with professionals who specialize in local country requirements for indirect taxes, taxes imposed by local or state/provincial jurisdictions, international tax and interest calculations for late payment that invariably affect the outcome.

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Business model optimization (BMO) 

The global economic environment is characterized by continuous improvements in technology, urgency to adopt and implement best practices and processes, and the potential for legislative changes. Assessing a multinational’s global business model is no longer an optional exercise. Business model optimization (BMO) is the process of balancing the demands of operations and tax law and integrating them into the business model. This helps ensure tax planning does not curtail the bottom line and that the business model does not surrender some or all of the value it creates. Deloitte provides high quality, customized tax and BMO services that focus on helping multinationals integrate operational and tax planning in a scalable and sustainable way in order to enable business leaders to make more effective decisions on an after-tax basis.

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Other tax services

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Deloitte delivers deep knowledge of tax and statutory requirements as well as a breadth of experience applying them in practice worldwide. Practical, innovative tax services combined with our globally-managed tax compliance framework instills confidence that a consistent approach is followed in all jurisdictions.
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Our professionals help design strategies and structure global transactions to reduce customs duty payments and other international trade costs, increase duty recoveries and help ensure legal and regulatory requirements are met in a cost-effective manner.
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Our teams of tax specialists, lawyers, and former government auditors and Workers' Compensation Specialists from a wide range of industries work to help you recover cash to operate your business.
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Deloitte can help with timely planning and the application of technology-based compliance management solutions, thereby helping to reduce costs, reduce risk, and increase the confidence that nothing has been missed.
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Deloitte’s international tax professionals help multinational companies reduce taxes on earnings, enhance margins and grow their businesses through a wide variety of compliance and advisory services.
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Deloitte Legal professionals bring a strong combination of tax and legal knowledge to provide clients comprehensive guidance across a broad range of critical business issues.
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Deloitte can assist your company with effectively navigating the myriad of tax, accounting, legal, regulatory, cultural, and labour issues in cross-border transactions to help manage compliance risks and potentially enhance returns.
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Deloitte helps private companies, their owners, and individuals with substantial assets apart from businesses they directly operate to understand, plan and execute effective business and tax strategies.
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With practitioners who are fluently trilingual in engineering, tax and “CRA”, we have assisted thousands of public and private companies to realize a sizable R&D tax credit.
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Our accessible Canadian network of U.S.-trained tax professionals are linked to their U.S. colleagues, creating a powerful team for companies with operations in the United States.

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