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. The absence of transfer pricing documentation provides tax authorities with a strong case to adjust a taxpayer’s transfer pricing arrangements and impose significant penalties.
We partner with your team to ensure all transfer pricing compliance requirements are fulfilled which will assist in proactively defending your transfer pricing positions to the tax authorities.
Some Puerto Rican companies that obtain tax incentives have intercompany transactions with there related entities outside of Puerto Rico. We assist in setting the right transfer pricing prices to be compliant with the IRS and Puerto Rico transfer pricing regulations and prepare transfer pricing studies. This study will allow you to avoid mis-pricing on your next US tax return and protect you from penalties that can be as high as 40% of the additional taxes due.
Benchmarking comparable searches are critical to test arm’s length results.
We prepare benchmarking studies for wide range of industries both local and overseas. With access to the full license third party database, we are able to provide our services with a competitive rate while maintaining high standard of deliverable.
Whether you require a review and update of your existing internal transfer pricing policy, are integrating new businesses and want to develop a new policy taking the best of both, or don’t have anything in place, we can help understand your related party transactions to develop a practical transfer pricing policy.
A comprehensive transfer pricing policy goes beyond mere compliance. We assist in putting practical and supportable transfer pricing policies in place.
As part of the BEPS initiative, an action plan has been developed by the OECD including a new global standard on transfer pricing documentation. The new global standard aims to provide tax authorities with unprecedented transparency regarding companies’ global transfer pricing policies and financial results. Companies may be required to implement new procedures allowing them to gather the information required.
We assist with planning and preparing for this new global standard on documentation including the preparation of country by country (CbC) reporting template.
Tax auditors are increasingly turning their attention to transfer pricing issues. Our transfer pricing experts assist with tax audits and tax court proceedings. We assist with responding and performing additional analysis as required in response to a transfer pricing audit. We have excellent skills and experience in managing audits, defending documentation, transfer pricing positions, and minimizing penalties and interest. Our transfer pricing experts also have the experience advising on APAs and on MAPs.
The OECD has been looking at the impact on the international tax system of the digitization of the economy. Pillar I looks at reallocating taxing rights away from locations where physical activity is carried out towards market jurisdictions (where customers or users are). We assist with assessing the impacts of the proposed Pillar 1 with our internally developed financial models and also provide training's to help you understand the Pillar 1 proposal.
We assist with various additional transfer pricing projects such as operationalizing transfer pricing calculations, assistance in drafting inter-company agreements, mergers and acquisitions, domestic transfer pricing planning, BEAT & FDDIE calculations, and restructuring projects. We also provide training on any transfer pricing topics i.e., Country by Country Reporting, transfer pricing documentation, OECD Pillar 1, etc.
Do you have clients who require assistance with transfer pricing but you don’t have the expertise? We team with your clients to provide transfer pricing services. We ensure your client relationship is paramount and will be pleased to involve us.