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Nilesh
Ashar

Partner

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TRANSFER PRICING

In today’s rapidly changing transfer pricing landscape, having an effective approach to managing transfer pricing opportunities, compliance and risk has never been more important.

Following OECD’s BEPS Action Plans, Transfer Pricing is now a big focus in the region especially with introduction of detailed transfer pricing regulations issued in the Kingdom of Saudi Arabia and Egypt. Further, groups headquartered in the region, need to keep pace with the rapidly evolving transfer pricing landscape in other jurisdictions housing their group entities/ business presence, particularly in light of Country by Country reporting and notification requirements emerging in various countries as they join and implement their commitment to the BEPS Inclusive Framework.

The changing regulatory environment precipitated by the BEPS initiative creates both opportunities and risks. With an extensive global network of leading transfer pricing practitioners, WTS Dhruva Consultants, along with member firms of WTS Global, is uniquely positioned to advise multinational companies on how to build, optimise, monitor, and defend their transfer pricing policies in a “post-BEPS” world.

What we do?

Transfer Pricing Risk assessment

Not all intra-group transactions are undertaken with a view to avoiding payment of taxes. We help MNEs manage their transfer pricing risks, strengthening their TP documentation and obtain greater assurance regarding their tax and transfer pricing positions in compliance with internationally accepted transfer pricing principles and local Transfer Pricing laws.

Transfer Pricing Planning

We help clients in developing and implementing transfer pricing policies for their proposed and existing intra-group transactions, document policies and outcomes which would help meet business and commercial objectives and at the same time reduce the risk of adjustments and penalties by tax authorities during audits. This includes:

  • Developing the most optimum transfer pricing methodology for inter-company transactions
  • Undertaking appropriate benchmarking studies to arrive at arm’s length price
  • Developing the transfer pricing policy document to document the pricing mechanism
  • Review of inter-company agreements from a transfer pricing perspective
  • Supporting clients in implementation of transfer pricing policies and undertake periodic reviews to identify any gaps.
Transfer Pricing Documentation

A robust and comprehensive transfer pricing documentation is the first step and serves as the first line of defense when tax authorities challenge a company’s transfer pricing practices.

We help clients in meeting local and global Transfer Pricing documentation requirements. This includes:

  • Local File/ Local Transfer Pricing documentation preparation in line with the requirements as per the local transfer pricing laws and the experience gained during Income Tax/ Transfer Pricing Audits
  • Master File preparation in line with the requirements as per the local transfer pricing laws and aligned with OECD requirements
  • Country by Country reporting, meeting notification requirements and assessing the exposure and transfer pricing risk for clients on account of submission of such data relating to global operations to tax authorities in different jurisdictions in which the multinational group operates.
Transfer Pricing advisory services

We assist clients in meeting their business objectives and advise them on their specific queries and pressure points including the following:

  • Alignment of transfer pricing policies with commercial objectives
  • Review existing inter-company arrangements and assess whether any tax efficiencies may be built into the documentation
  • Supply chain transformation to ensure that transfer prices are in line with value creation
  • Profit attribution to Permanent Establishments