Linkedin
Facebook
Email
more
Transfer pricing presents significant risks and opportunities for multinational groups.
As the global landscape evolves, tax authorities are seeking to prevent base erosion, impacting multinationals of all sizes and in all sectors. Risks arise where a failure to prepare renders insufficient evidence of compliance, whilst alignment of commercial tax strategy creates opportunities for efficiency and transparency.
In many jurisdictions, including New Zealand and our major trading partners’, tax authority scrutiny is leaving no stone unturned. Intangibles, financing, business restructurings, low profitability, hub arrangements, and a heightened focus on economic substance are keeping taxpayers and advisors on their toes as tax authorities look for stronger assurances that they are not missing their "fair share" of value chain profits.
Transfer pricing cannot be considered simply from the perspective of one jurisdiction; adopting a conservative position in one jurisdiction may in fact drive risk in other markets.
As such, an holistic and balanced approach is required, supported by commercial judgment and deep industry expertise.
Our approach to managing risk
RSM optimises the process of establishing and defending your transfer pricing positions by offering a tailored assessment of your cross-border tax risks to support internal risk management.
- Enabling internal transparency and process improvement through understanding of pricing, margins, and global costs;
- Demonstrating the current and future value drivers that may contribute to your cross-border tax positions;
- Managing if not eliminating exposure to penalties from transfer pricing adjustments;
- Reducing the internal work required in the event of tax authority risk review or audit if no documentation was available;
- Providing a basis upon which to demonstrate compliance with accounting standards relating to "uncertain tax positions”;
- Evidencing the role that transfer pricing has played in appropriate tax corporate governance.
Our capabilities
RSM is focused on understanding the value drivers of your business to assist in establishing an operational tax and transfer pricing model that’s fit-for-purpose and aligned to the arm’s length standard.
- Diagnostic risk assessments of existing cross-border arrangements
- Advice on different operating models, their effectiveness, and associated risk factors
- Preparation of transfer pricing policy and governance frameworks, and contemporaneous documentation, including benchmarking tailored to your needs
- On-hand support to implement and monitor transfer prices, including cost allocation analyses
- Negotiation and renewal of Advance Pricing Arrangements with tax authorities
- Assistance and support in responding to tax authority reviews and audits
- Pricing of intercompany loan arrangements, with specific focus on New Zealand’s unique restricted transfer pricing regime
- Assessment of the development, enhancement, maintenance, protection and exploitation (DEMPE) of business intangibles
- Mapping Country-by-Country Reporting obligations and managing resulting compliance requirements
- Preparation of analyses to substantiate the arm’s length nature of business restructures and compensation payments
- Review and drafting of intercompany agreements to ensure legal form aligns with economic substance, including cost sharing arrangements
- Assisting in seeking Advance Pricing Arrangements with tax authorities
- Assisting in responding to tax authority reviews
