Cross-border related-party pricing and international tax must be assessed together when group companies exchange goods, services, funding or intellectual property.
Understanding Transfer Pricing & International Tax Advisory
When to consider this service
Taxpayers, finance teams and group tax managers reviewing a transaction, a reporting requirement or an authority communication can use this service to clarify a particular issue. A useful starting question is: “Does transfer pricing analysis cover every international tax issue?” Begin with the facts behind that question rather than assuming that a standard package will resolve it.
Scope of work
The engagement can cover the following workstreams. The proposal specifies which apply to your matter and what evidence or specialist input is needed.
- Map related parties and transaction flows.
- Compare pricing methods with business functions.
- Review treaty and permanent-establishment questions.
Documents and information to prepare
Start with the records below where available. They help establish the facts before a more specific checklist is agreed.
- Intercompany agreements.
- Entity charts.
- Transaction ledgers.
- Country-wise financials.
Provide the relevant entity, transaction or reporting period and any existing notice or deadline. Identify missing or inconsistent records so they can be addressed explicitly.
A key issue to resolve
An arm’s-length price does not by itself resolve withholding, treaty entitlement or permanent-establishment exposure.
How the engagement works
- Define the question: map related parties and transaction flows, using the available intercompany agreements and the facts you provide.
- Examine the evidence: compare pricing methods with business functions. Record unresolved information and the assumptions that affect the analysis.
- Agree the action: review treaty and permanent-establishment questions. Set the required deliverables, responsible owners and any follow-up or external dependency.
Deliverables, fees and timing
The proposal for Transfer Pricing & International Tax Advisory sets out the analysis, documentation or coordination deliverables and the work you retain. The availability of intercompany agreements, entity charts, transaction ledgers and country-wise financials affects readiness and the amount of follow-up needed. Fees and the working schedule are agreed after that initial assessment. Any required independent report, legal representation or authority application is identified as a separate responsibility where relevant.
Official resources
Use these official resources for the relevant framework. Application to a particular entity, period or jurisdiction requires a separate assessment.
Discuss your requirement
Share a short summary of your Transfer Pricing & International Tax Advisory requirement and the records already available. BIATConsultant can assess the proposed scope and explain the next steps.
FAQ
Practical questions about Transfer Pricing & International Tax Advisory.
Does transfer pricing analysis cover every international tax issue?
An arm’s-length price does not by itself resolve withholding, treaty entitlement or permanent-establishment exposure.
What records should I prepare for Transfer Pricing & International Tax Advisory?
What can the scope of Transfer Pricing & International Tax Advisory include?
How are fees and the schedule agreed?