Typical examples of transfer pricing requirements, solutions and benefits are as follows:
| Issue / Requirement | Potential Solutions | Value/ Benefits |
| Assurance - the ability to set prices that produce intended financial results that are supportable and provide certainty |
Practical transfer pricing policy design and implementation Documentation and rulings to support policy Proactive pre-return engagement with tax authorities |
Control over transfer pricing risks and management of effective tax rate and regulatory risks Prevention of audits by managing tax authority relationships |
| Tax efficiency - to take advantage of planning opportunities that can be aligned with business needs and that comply with regulatory and tax authority requirements |
Identify and quantify benefits arising from effective exploitation of intellectual property. Designing transfer pricing transactions that support changed business structures Provide documentation and implementation |
Sustainable lower effective tax rate Relief for stranded losses Control over audit and regulatory risk Transfer pricing is aligned with business operations Improved cashflow/cost control |
| Dispute resolution - to resolve transfer disputes effectively, minimising tax adjustments, double taxation, interest, penalties and damage to reputation |
Advice on strategy for handling audits, litigation & arbitration Negotiation with tax authorities Economic analysis to refute tax authority position |
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| Financial transactions/Capital Structure (Thin Capitalisation management) - to ensure that debt is priced and structured in a tax efficient and supportable manner |
Advice on supportable borrowing capacity and interest rates Negotiation of thin capitalisation, withholding tax and anti-avoidance rulings with tax authorities |
Management of effective tax rate by maximising interest deductions Assurance that tax authority obligations are met |