Transfer Pricing Documentation

The documentation of an established transfer pricing methodology is not only vital to defending cross jurisdictional pricing between connected parties but also mandatory in many international jurisdictions. Duff & Phelps can assist by documenting the application of the OECD Guidelines using established best practice which will provide tax authorities (should they wish to see it) with a clear and logical approach to the determination of the arm’s length pricing for cross boarder services rendered.

Our service includes:

  • Reviewing current structures for established groups, to ensure appropriate arm’s length charges are made for tax purposes:
  • Reviewing income flows and service levels provided by respective entities
  • Providing comparable financial data from a range of similar businesses to the entity
  • Recommending reasonable income flows, based on comparable data and specific factors applicable to the entity
  • Providing a transfer pricing report, documenting findings and recommendations.

We aim to ensure that inquiries from tax authorities are less likely to occur due to viable transfer pricing policies. Transfer pricing reports which evidence the background for policies, will address most initial queries in the case of an inquiry. However should a tax authority disagree with the pricing we are at hand with our extensive industry knowledge to resolve any dispute.

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