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Your issues – our solutions – your benefits

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

  • Better settlement results – lower liabilities
  • Less management time diverted
  • Certainty regarding liabilities
  • Maintain relationship & credibility with tax authorities
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

National contacts

David Sayers

David Sayers

Partner
+44 (0)1908 257200

Dominic Pickard

Dominic Pickard

Partner
+44 (0)7798 808 408