Transfer pricing involves setting prices for transactions between related entities within a multinational enterprise (MNE). Proper transfer pricing ensures compliance with tax regulations and avoids double taxation, while also optimizing financial efficiency. At SRCO, we offer comprehensive transfer pricing services to help your organization navigate complex regulations, optimize tax positions, and ensure compliance. Here’s how we can assist you:
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Transfer Pricing Policy Development:
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- Develop transfer pricing policies that align with your business operations, strategies, and objectives, ensuring compliance with local and international regulations.
- Create and document transfer pricing methodologies that reflect the economic realities of intercompany transactions and are defensible to tax authorities.
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Transfer Pricing Documentation:
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- Prepare comprehensive transfer pricing documentation, including Master Files, Local Files, and Country-by-Country (CbC) reports, in accordance with OECD guidelines and local regulations.
- Ensure documentation is accurate, up-to-date, and provides a robust defense against transfer pricing audits and disputes.
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Advance Pricing Agreements (APAs):
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- Assist in negotiating and securing Advance Pricing Agreements (APAs) with tax authorities to obtain certainty on transfer pricing arrangements and mitigate audit risks.
- Prepare APA submissions, coordinate negotiations, and manage compliance with APA terms and conditions.
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Transfer Pricing Compliance and Reporting:
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- Ensure timely and accurate preparation and submission of transfer pricing reports, disclosures, and filings required by local tax authorities and international regulatory bodies.
- Monitor changes in transfer pricing regulations, tax laws, and international guidelines to maintain compliance and adjust strategies accordingly.
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Risk Assessment and Management:
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- Identify and assess transfer pricing risks, including potential adjustments, penalties, and interest charges, to proactively manage and mitigate risks.
- Develop risk mitigation strategies, internal controls, and governance frameworks to enhance compliance and reduce the likelihood of transfer pricing disputes.
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Transfer Pricing Audit Support:
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- Provide support during transfer pricing audits, including responding to information requests, defending transfer pricing positions, and negotiating with tax authorities.
- Prepare robust audit defense files, conduct mock audits, and provide expert witness testimony if required.
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Training and Capacity Building:
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- Offer transfer pricing training programs and workshops for finance, tax, and legal teams to build internal expertise and awareness of transfer pricing regulations and best practices.
- Provide ongoing support and advisory services to address transfer pricing queries, updates, and challenges.
By partnering with SRCO for transfer pricing services, you can achieve compliance with global transfer pricing regulations, optimize tax positions, and minimize risks. Contact us today to discuss your transfer pricing needs and discover how we can help you navigate the complexities of transfer pricing with confidence and efficiency.