Transfer Pricing Structuring and Design
Transfer Pricing Structuring and Design

Rome was not built in a day, neither was it built without a design and plan. Similarly, a global multinational business is not built without a thoughtful plan and structure. A blueprint and design is of essence while drafting and creating a pipeline for undertaking global transactions between the multinational companies.

Transfer Pricing design should support your business and must be simple and compliant. In addition, it should make use of available tax incentives. Your structure should be prepared in a way that suits your multinational group’s ideology of business. So, it is not a one size fit all concept. Designing a transfer pricing structure comes with experience and you should look at the experience that a firm brings to you while you think of structuring your cross-border transaction.

We always look at the larger picture and take the long-term vision of the company into account. The depth of our analysis will depend on the size and complexity of the company or division. Our analysis typically increases business insights, saves administrative efforts, limits tax risks and may have a positive impact on the effective tax rate.

  • Transfer Pricing Policy and price setting

    Setting up of price and documenting the same is like building a pipeline for the transactions to flow. Set the price mechanism for once and undertake your transactions on consistent basis, thereby mitigating the tax risk in future. We can help you documenting the transfer pricing policy for the group.

  • Inter Corporate Agreements

    ICA provides a legal backing to the realities of transfer pricing. An ICA is instrumental in assigning the roles and responsibilities between the transacting party, thereby helping in narrowing down on the remuneration model and the degree of remuneration. We can help put together an ICA for the transaction under consideration.

  • Group Profit Management

    Managing global profitability is an art over science. It is essential to pick right tax holiday’s and breaks at a group’s level to bring down the global tax impact on the profitability. In technical terms it is called as managing the Effective Tax Rate. With our experience with global groups, we have been engaged in several group profit & tax management ultimately resulting in reduction of global effective tax rate. It is said that savings in 1% tax reduction is equal to 30% increase in sales.

  • Specific transactions

    For dealing with special transaction one needs an in-depth understanding of the subject combined with analytical approach and experiences. We have provide expert advisory on transaction structuring for transactions involving financial transactions / interest/ loan benchmarking, cost contribution agreements, management fees, Intra-group Services, intangible structuring including royalty structures etc.

  • Transfer Pricing Review

    Once a structure is built, it often needs consistent maintenance and checks to assure that the process is working well and is followed with checks and controls. This involves periodic review of the structure in place whereby analysing the management reports/ MIS, we can advice on whether the implemented framework is meeting its goal.

  • Transfer Pricing due diligence

    Global mergers and acquisitions/ funding/ takeovers are undertaken in a way that investors need clarity on the transfer pricing risk involved in the operations of the target company. We support such an objective by undertaking a detailed audit exercise on the transfer pricing model of the target, thereby evaluating the risks in the model as well as solutions to mitigate the risk.