Transfer Pricing Risk Reviews and Audits are a focus point of the Tax Authorities around the world as a result of the global focus on BEPS. Tax Offices worldwide are focusing on transfer pricing and many businesses are found to have insufficient support for their cross-border prices. The absence of transfer pricing documentation provides tax authorities with a strong case to adjust a taxpayer’s transfer pricing arrangements. Without such documentation, it is more difficult to argue against any Tax Office adjustment.
We will team with you to document your company’s business and international related party transactions and the economic analysis of transactions through benchmarking and other analysis. Contemporaneous transfer pricing documentation will assist in proactively defending your transfer pricing position in front of the tax authorities in the Asia Pacific Region.