Transfer Pricing Advisory

In today’s post-globalization environment, every nation is subject to the international tax framework, which includes Transfer Pricing as one of its core ideas. Multinational Enterprise (MNE) groups have a distinct set of issues as a result of the Base Erosion and Profit Shifting (BEPS) concept’s focus on taxing value creation, as well as rising volumes and regular operational transactions. Transfer Pricing is a crucial issue for many international businesses in the context of a constantly changing global regulatory environment as well as improved local compliance efforts.

Transfer pricing is the pricing offered by one MNE group member for the exchange of goods, services, money, and other intangibles with another MNE group member located outside of the country. Such international intra-group transactions are becoming commonplace. It takes a lot of time and effort for taxpayers to comply with the numerous, constantly expanding requirements that apply to these transactions between countries. Businesses may have less time and money to make strategic and financial decisions as a result. Through multilateral agreements, automatic information exchange (AEOI) and country-by-country reporting (CbCR) allow tax authorities around the world to instantly communicate data on international related party transactions (RPTs).

For MNE groups, transfer pricing is a constant process and a crucial area of scrutiny that calls for a high level of expertise, time, and effort. MNEs should, therefore, use a systematic strategy for TP risk management and controls along with compliance requirements such documentation, TP study (local file), master file, TP records and processes, etc.

At Bestfolio, we help taxpayers with files and prompt and correct compliance since we have a thorough understanding of the compliance requirements under local Transfer Pricing regulations, CbCR regulations, and tax legislation in numerous countries. For reliable and long-lasting end-to-end TP solutions, our transfer pricing experts and tax advisors with international experience are your one-stop resource.

With a defined Transfer Pricing strategy that satisfies regulatory requirements and is in line with your long-term company objectives, Bestfolio assists you. We provide TP models that, through ongoing financial analysis and prompt action, are in line with your value chain, resonate with it, and can adapt to changing company conditions. We make sure that all transactions involving related parties are recorded to put your transfer pricing model in line with legal requirements. Our staff reduces the risk of non-compliance while guiding you through difficult international tax topics.

We assist with Transfer Pricing as follows:

• Support on your existing TP policies and in complying with documentation requirements
• Assist with implementing new TP models
• Assist with the BEPS impact

Our range of TP Advisory services includes:

• Transfer Pricing -related due diligence advisory
• TP health check, correction of gaps identified from accounting records
• Devising tax efficient and globally defensible TP models in sync with commercial business activities, international TP best practices; OECD BEPS and UN TP Manual based guidance
• Advising MNE groups on TP related business restructuring and supply/value chain analysis and transformations (VCTs)

• Assistance in drafting TP policies based on pre-benchmarking
• Drafting and vetting of agreements from a TP perspective
• Assistance in implementation of TP models
• Analysis TP & Tax Updates/ developments to see how they impact current transactional arrangements and TP policies
• Advice on interplay of TP policy with Customs valuations
• Advice on legal vs. beneficial ownership of intangibles and on other aspects under BEPS AP 8-10 (aligning TP outcomes with value creation)

Our TP Compliance and Litigation support services includes:

• Preparation of Transfer Pricing Documentation as per the Local TP & Tax law requirements, as applicable and BEPS guidance, containing industry and group overview, functional, and economic / benchmarking analyses of RPTs against the industry margins and evaluation of Transfer Pricing methods.
• Assist with preparing the TP Policies,
• Assisting with TP certificate, form filings and related disclosures in tax returns as per respective country TP laws