Transfer Pricing

Taxation Services

Helping you succeed in international markets

Transfer Pricing is typically one of the most significant tax issues for multinational groups, given its subjectivity and the increasing concern of tax authorities worldwide to ensure profits are not inappropriately shifted through non-arm’s length pricing. In many jurisdictions, this has been exemplified by tax authority scrutiny of a number of arrangements and a continued general focus to ensure they are not missing out on their ‘fair share’ of the overall value chain's profits.

However, Transfer Pricing risks cannot be considered simply from the perspective of one jurisdiction: adopting a conservative position in one jurisdiction will put pressure on transfer pricing risks in other jurisdictions. As such, a holistic and balanced approach is required - as well as the exercise of sound professional judgment and expertise.

RSM's approach is to assist multinationals in establishing a transfer pricing policy that is ‘fit for purpose’, so the global value chain is remunerated appropriately and the support for this is appropriately documented. This has four key benefits:

Reducing or potentially eliminating the exposure to penalties from an adverse transfer pricing adjustment
Providing a basis upon which groups can demonstrate they have complied with accounting standards relating to ‘uncertain tax positions’.
Significantly reducing the internal work that would otherwise be required, in the event of tax authority audit if no documentation was available
Evidencing sound corporate governance

Our Transfer Pricing capabilities include:

Conducting risk assessments of existing Transfer Pricing arrangements
Advising on different Operating Models and their effectiveness/appropriateness
Preparing Transfer Pricing policy frameworks
Transfer Pricing policy implementation support services, including cost allocation studies
Preparing Transfer Pricing documentation
Managing Country-by-Country Reporting compliance obligations
Preparing Business Restructuring ‘support files’ to substantiate restructurings
Reviewing legal agreements to ensure legal form aligns with economic substance, including cost sharing agreements
Assisting in seeking Advance Pricing Arrangements with tax authorities if these are provided for
Assisting in responding to tax authority reviews