Baker Tilly can help you with transfer pricing issues
Transfer pricing planning and advisory
Tax authorities are increasingly vigilant to occurrences of base erosion and profit shifting and insist that intra-group transactions be set at an arm’s length basis. Regardless of company size, we work closely with clients to best understand their situation and transform their transfer pricing concerns into opportunities and solutions. With international taxation becoming one of the biggest issues facing multinational enterprises and individuals, Baker Tilly can assist with the following services:
- Prepare and review transfer pricing policies which satisfy all applicable tax jurisdictions and requirements of the OECD BEPS Action Plan
- Establish transfer pricing documentation guidelines
- Advise on special transfer pricing issues, including: support for valuing certain intangibles, support establishment of tax-aligned supply chain structures, identification and potential mitigation of permanent establishments, support design of personnel secondments and support with tax and transfer pricing issues related to intra-group financing
Transfer pricing documentation
Increased scrutiny by tax authorities across the globe has highlighted the importance of a properly documented transfer pricing arrangement. In the case of an audit, companies with inadequate documentation are subject to severe financial penalties. As part of its BEPS Action Plan, the OECD has introduced recommendations and increased transfer pricing documentation requirements. We will team with you to not only meet compliance requirements, but also to comprehensively assess and plan for potentially unseen transfer pricing issues by providing services such as:
- Assessment of current transfer pricing documentation (e.g. master file, local file, intercompany agreements etc.) for sufficiency and provide revision as necessary
- Preparation of customized benchmark studies in order to determine reasonable intra-group prices
- Compilation of applicable compliance documentation such as country-by-country reporting (CbCR)
Tax audit and dispute support
Transfer pricing investigations are often stressful situations for companies. Mismanaged audits can result in double taxation, interest and penalties. Therefore, audits must be approached with a team that can dedicate the required attention to the matter. We work closely with our clients in responding to such challenges.
Design and implementation of transfer pricing systems and restructuring business function
Business restructuring should be undertaken with respect to the arm’s length principle. Both tangible and intangible assets, which may be transferred across jurisdictions during such restructurings, must be valued in such a manner that is defensible to scrutiny. Intercompany agreements that clearly reflect arm’s length pricing as well as clarify all related functions is critical in ensuring compliance. Running afoul of these principles can result in exceptionally increased tax liabilities.
Drawing from our extensive transfer pricing experience, we work closely with our clients to ensure their businesses have the most efficient and effective systems in place.