Tax authorities worldwide are now developing regulations that will protect their tax revenues in particular to anticipate expansion of MNE in their jurisdiction. The recent MNE expansion creates intensive movement of capital and resources worldwide. The issue, currently being main concern of most tax authorities, is whether the pricing and conditions imposed in related party transactions is arm’s length compared to the pricing and conditions imposed in the transactions entered into by independent parties with the similar circumstances.
Transfer pricing is now becoming issues to tax authorities worldwide, because transfer pricing can be used to shift income and assets from one jurisdiction to other jurisdictions with favorable tax rate. By these reasons, tax authorities worldwide have increased challenges for MNE from detailed transfer pricing regulations to complex documentation requirements. MNE are now seeking for advice in structuring related party transactions within the group at the same time they have to comply with the increasing regulation and intense scrutiny.
At TaxPrime, our division of transfer pricing comprises experienced professional that can help MNEs in the following services :
- Transfer Pricing Planning-to assist in developing transfer pricing and tax planning strategies through structuring tax-efficient supply chain and business operations and many other ways
- Transfer Pricing Documentation-to assist in preparing contemporaneous transfer pricing documentation which can mitigate risk within current transfer pricing regulation, documentation requirements, transfer pricing audit, transfer pricing in indonesia and significant penalties for noncompliance.
- Transfer Pricing Diagnostic Review-to assist in implementing sound strategies and processes that may provide defensible model, and safeguard against tax audit and disputes. We can perform review of your overall transfer pricing documentation and inter-company arrangements to identify opportunities for structuring tax-efficient business operation and recommend best practices for your inter-company transactions.
- Benchmarking studies-to assist in preparing benchmarking report for related party transactions which comprises searching and selecting comparable uncontrolled transactions determined through analysis of function performed, risk assumed and asset used.
- Dispute Resolution-to provide service in resolving transfer pricing dispute through either global and local level. We perform assistance with Advance Pricing Agreement (APA), Mutual Agreement Procedure (MAP), competent authority negotiation, arbitration, tax objection, and tax appeal.
- Transfer Pricing in-house training-to conduct transfer pricing training for company’s employees which can be tailored as company’s requirement in particular subject of transfer pricing or the tiered training specially designed by TaxPrime which comprise basic, intermediate, and advance level.