BEPS Contract Analysis

It is designed to assist clients in drafting intercompany contracts that are consistent with the OECD BEPS requirements on the management and sharing of risks.

Value Chain Alignment (VCA)

(VCA) supply chain planning uses arm’s length transfer pricing guidelines, applied to a center-led business model (that is the Principal Operating Company (POC)), as well as customs and other indirect tax planning to embed tax efficiency into a company’s operating model.

Intangibles

Planning support includes financial modeling, documentation of planning assumptions, and plan transition and reconciliation. Full scope valuation includes expert opinion valuations and indicative valuations (with or without plausibility checks).

Goods & Services

Helps maintain and improve our benchmarking capabilities, which includes TNMM benchmarking technical discussions, search matrices, automatic translation guidance, common standards, and benchmarking databases.

Financial Transactions

Transfer Pricing service line has invested in a framework for delivering transfer pricing debt pricing services in a consistent, efficient, and cost-effective manner.

Country by Country Reporting (CbCR)

In essence, large multinationals will have to file an annual report, the CbC Report, that breaks down key elements of the financial statements by jurisdiction.  Deloitte assists clients in strategically determining the overall approach, constituent entities and associated tax jurisdictions of residence, business activity code selection, financial data sources, definition interpretation, data mapping and the CbC report preparation.

TP Documentation Toolkit

The "TP Documentation Toolkit" is a common framework to deliver transfer pricing documentation reports globally in a consistent, efficient, and cost-effective manner. The TP Documentation Toolkit is scalable and applicable for ALL types of TP documentation projects. Organized by phases, modules, and tasks, the TP Documentation Toolkit provides you with easy access to content, resources, tools and templates in each corresponding task.

Operational Transfer Pricing (TP) Our Operational TP offering (OTP) aligns the areas of a TP lifecycle (plan, manage, and resolve) to facilitate a holistic view of transfer pricing in the business. We have resources to help clients review their current processes, recommend process improvements to the collection and use of data, construct a business case, implement, and monitor their operational transfer pricing.

Dispute Prevention

Our dispute prevention offering provides tools and resources to help clients proactively manage their controversy issues. This includes: planning and preparation to minimize disputes, documenting and preparing evidence and defense files, developing global strategic controversy-aware TP policies, bilateral and multilateral APAs, advanced rulings and unilateral APAs, pre-transaction engagement with tax authorities, and ongoing proactive engagement with tax authorities.

Dispute Resolution

Our dispute resolution offering provides tools and resources to help clients manage their disputes with tax authorities. This includes: transfer pricing inquiry handling and closure, global inquiry process tracking, interaction with tax authorities, economic and technical support, appeal and litigation support, MAP and arbitration support, and diverted profit tax regimes.