Transfer Pricing Service

We support companies in managing transfer pricing audits across jurisdictions and addressing disputes arising from transfer pricing adjustments. Our services include reviewing and refining responses to information requests and supplemental explanations, developing audit defence strategies, supporting communications and negotiations with tax authorities, and assisting with subsequent appeals procedures.

Transfer pricing documentation refers to a set of transfer pricing reports and other supporting documents, used by enterprises to demonstrate compliance with the arm’s length principle. Transfer pricing documentation provides broad disclosure of key information, including the transaction details, functional and risk analyses, and arm’s length pricing assessments. This enables enterprises to effectively respond to tax audits and reduce exposure to transfer pricing adjustments and penalties. From a risk management perspective, proactively establishing robust transfer pricing documentation enhances tax transparency and provides critical support in the event of disputes, forming a first line of defence while strengthening audit readiness and supporting informed management decision-making.

Advance Pricing Agreements (APAs/BAPAs) and Mutual Agreement Procedure (MAPs) advisory services are designed to help organizations reduce tax uncertainty in controlled transactions. APAs/BAPAs enable taxpayers and tax authorities to agree in advance on appropriate transfer pricing methodologies for specified transactions, while MAPs provides a mechanism under tax treaties for resolving double taxation through negotiations between tax authorities.

Our services include application strategy planning, documentation preparation, and support in communications and negotiations with competent authorities. APAs provide greater long-term tax certainty, while the MAPs serve as an important mechanism for resolving disputes at a later stage. Both are critical mechanisms for multinational enterprises to strengthen tax governance and risk management in high-risk transaction environments.