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Transfer pricing

Our Transfer Pricing (TP) Service is comprised of professionals who focus exclusively on providing the full range of transfer pricing services. Recognised as one of the world’s best, Deloitte’s transfer pricing practice employs a unified approach to understanding our clients’ business objectives and aligning our services appropriately for more effective transfer pricing solutions.

TP documentation

TP Documentation services cover Industry analysis, inter-company transaction analysis, functional and risks analysis, economic analysis and special factor analysis, with objectives to meet compliance requirement, achieve effective risk management and explore planning opportunities.

TP planning

TP Planning services cover review of existing structure and transfer pricing policy, identifying alternative structures and issues, conducting function/risk, financial analysis under the proposed structure, preparing documents to support the selected alternative structure and assisting in policy implementation, aiming to facilitate business development (growth, restructuring and cross-border investment), help design repatriation strategy and meet new regulation requirements.

Audit defense

Audit defense services help client handle transfer pricing audits from tax authorities, which generally include review, preparation and submission of replies and documentation for filing with the tax authorities, application for extension of time for submission of information to the tax officials, on-going advice on the appropriate strategy in dealing with tax officials' enquiries and challenges, communication with tax officials on behalf of our client. Audit defense services can effectively help our client avoid pre-mature transfer pricing adjustment.

Advanced Pricing Agreement

Advance pricing agreements (APAs) are advance agreements on transfer pricing methodologies, entered into by taxpayer and at least one government's administration. The services assist our client in rationalizing transfer pricing policy, selecting transfer pricing methodologies and determining profit/price target, discussions with tax authorities in the pre-filing meeting, preparing supporting documentation and formal application package for APA application and negotiating APA terms with tax authorities. The services intend to achieve risk-free pricing compliance and function as a viable alternative to contemporaneous documentation.

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