When two or more companies related in a Multinational Enterprise arranges all aspects of its pricing of trades on its goods and services in the global complex market, a transfer pricing occurs.
With globalization as a tough competition where intercompany and cross border transactions are more varied and increase in its volume, have made transfer pricing a great risk issue for global business. The concern of the tax authorities all over the world is that transfer pricing may be used by MNE’s to shift income and tangible or intangible assets from one country or jurisdiction to other countries or jurisdictions with a more favorable tax rate or no tax rate, hence a non double taxation may occur.
MNE’s must use the best and appropriate advice to make a strategy in restructuring their related party transactions within related party’s while at the same time they must be in line with the existing and new regulations by the tax authorities.With experience as transfer pricing auditors and practitioners from the Directorate General of Taxes, our Partners at TBrights is able to help you manage risks with practical transfer pricing solutions covering the whole business operation and targets. Starting from Transfer Pricing Review and Transfer Pricing Planning, we are also able to support you with strategic Transfer Pricing Documentations with analyzing you Transfer Pricing Comparable to support your international trade and transactions pricing thus help you resolve your disputes and audit efficiently and effectively. We also conduct benchmarking study, and make strategies from exact assessment methodologies to design inter-company transfer pricing policies adopted in each of your unique business operation. We also assist you in resolving your dispute issues with the Tax Authorites in tax objection, tax appeal, Mutual Agreement Procedure (MAP) and Advanced Pricing Agreement (APA).