Transfer Pricing Benchmarking, Planning, Monitoring, and Business Restructuring

The transaction with related parties is valid as long as it is conducted in accordance with the arm’s length principle. Therefore, planning and maintaining the transactions at arm’s length is indispensable. Additionally, OECD has declared to prevent and avoid any base erosion , and profit shifting by aligning the transfer pricing outcome with the value creation, i.e., the function performed, an asset used, and risk assumed. Therefore, the transfer pricing arrangement in this era should reflect how companies economically create value. The traditional structure that only focuses on formal/legal structures may be at high risk and prone to further scrutiny from tax authorities which seek the substance of the arrangement. 

Our services would ensure that our clients’ planned transfer pricing policies and structures fulfill the OECD Guidelines and prevailing domestic regulation; therefore, further scrutiny and disputes with tax authorities would be minimized in case the policies and structures were conducted.