At arm’s length
Tax authorities are becoming more and more aware of the importance of cross-border activities and transfer pricing. By making creative use of differences in international taxation, companies tend to allocate costs to high tax countries and revenues to low tax jurisdictions.
However, the OECD guidelines on transfer pricing require that inter-company transactions should be carried out at arm’s length.
Whenever your company engages into cross-border services or deals with associated companies abroad, the question arises whether the transfer prices that you apply will be at arm’s length and whether the applicable documentation requirements are met. In this area we have a lot of expertise in assisting you, inter alia, with the review, documentation, management and protection of your transfer pricing policies and processes.
We can advise you on how to set up an optimal international holding, royalty or finance structure, import / export structures, transfer of IP and many other situations where cross-border transactions and services are involved.
We have extensive knowledge and experience of transfer pricing legislation and corresponding documentation requirements. Over the years we have developed a strong network of transfer pricing professionals who can assist you abroad.
Proper anticipation on national transfer pricing legislation brings security and peace of mind when it concerns your international business structure. If so desired we can liaise with local tax authorities and tax professionals to arrive at proper transfer prices for your transactions.
We can assist you in identifying a proper transfer pricing methodology for your specific type of business ensuring that compliance requirements are satisfied and minimising the risk of transactional or net adjustments. We will inform you on how to utilise differences in tax regimes between jurisdictions.
This is of importance as tax authorities worldwide are now increasingly scrutinising cross-border transactions, imposing more penalties, demanding additional documentation, engaging into increased exchange of information, tax audits, etc. We know how to steer clear of these.