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Transfer pricing

coin jarsMultinational organizations 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.  

The goal of Deloitte member firms’ (Deloitte) 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 

Tax risks and tax authorities’ claims significantly impact business operations, and often the very existence of a business, in Russia. Russian tax laws are full of gaps and ambiguities which can adversely affect the development of your business. Moreover, the taxpayer often faces opposition from the tax authorities when claiming a tax refund, during the consideration of objections to the results of tax audits, or when appealing the unlawful decisions of tax authorities and officials. Learn more.

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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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Learn more

  • The Link Between Transfer Pricing & Customs Valuation - 2012 Country Guide
    Planning for methods, documentation, penalties, and other issues
  • 2012 Global Transfer Pricing Country Guide
    Planning for methods, documentation, penalties, and other issues

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