Unsere Dienstleistungen - Ernst & Young - Schweiz

Unsere Dienstleistungen

Our Transfer Pricing/ TESCM practice has the experience and resources to provide different services, based on different levels of support, to satisfy each individual client’s objectives. Each service is flexible enough to address the issues of concern to the multinational company or entrepreneurial companies just starting to grow their international operations.

In accordance with the needs of the market to serve clients large and small, our services have been grouped according to four broad categories:

• Transfer Pricing Planning
• Tax Effective Supply Chain Management
• Global Documentation
• Controversy Management

Transfer Pricing Planning

Many multinational companies overpay their taxes on a worldwide basis and can achieve significant reductions through revised transfer pricing practices. By integrating transfer pricing planning, documentation and controversy into a unified platform, Ernst & Young helps clients manage their transfer pricing position globally.

Our services with respect to transfer pricing planning include:

• Advising on the development and implementation of worldwide transfer pricing policies
• Advising on headquarters service fee charges
• Advising on intellectual property planning, including royalties, cost sharing and R&D
• Analyzing and assisting with the implementation of changes with regard to the shifting of functions, risks and/or intangibles (e.g., changes to contract manufacturers, commissionaire sales subsidiaries, etc.)
• Assisting with the advance pricing agreement (APA) or tax ruling process
• Advising on the customs implications of existing or revised transfer pricing policies

Tax Effective Supply Chain Management (TESCM)

All over the world, enterprises are redesigning functions, implementing new structures and re-engineering flows of goods and services to reduce costs and improve business processes. Thinking about tax issues up-front can lead to the optimal supply chain structure.

Our TESCM services include:

• Advising on worldwide tax (direct and indirect) reduction strategies
• Advising on the use of applying transfer pricing principles to support the desired business and tax structure
• Analyzing means to reduce product costs by integrating customs planning in supply chain design

Global Documentation

An increasing number of countries now impose transfer pricing documentation requirements, most of which can be onerous for affected businesses. Using finely tuned methods to efficiently document transfer pricing policies, dedicated specialists – including economists and tax professionals – can provide an integrated, multi-country approach to meeting documentation obligations.

Our global documentation services include:

• Preparing/ reviewing documentation to meet foreign documentation requirements
• Preparing a global master documentation which can be tailored to country-specific needs
• Preparing/ reviewing intercompany agreements documenting arm’s length transfer pricing

Controversy Management

As fiscal authorities become more aggressive in applying their transfer pricing regimes, disputes are bound to arise.

Our Controversy Management services include:

• Advising clients for defense on audits
• Assessing economic strength of the fact patterns of clients approaching audit or litigation
• Directing clients’ fact finding and developing economic defense for clients during audit