Transfer Pricing Audit Defence

Due to the profound impact of Base Erosion and Profit Shifting (BEPS) action plans, related-party transactions and pricing arrangements of multinational corporations are usually scrutinised by tax authorities under their anti-avoidance spotlight and give rise to more transfer pricing investigations than ever.

With extensive experience in the field of transfer pricing, we are capable of conducting risk assessment for related-party transactions and advising on pricing policies to mitigate transfer pricing risks that our clients may face. We have successfully represented our clients in negotiation with the tax authorities to settle pricing disputes in challenging and high-profile transfer pricing audits, and achieved outcomes that far exceed clients’ expectations.

Our transfer pricing services cover

  • Transfer pricing analysis, including industry benchmark analysis
  • Pricing policy planning for related-party transactions and preparation of transfer pricing documentation
  • Optimisation of business model in related-party transactions
  • Transfer pricing audit defence and negotiation
  • Unilateral and bilateral advance pricing arrangement (APA)
  • General anti-avoidance investigation defence
  • Defence on import price of related-party transactions
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