Transfer Pricing Services

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Transfer Pricing Services

Melenco has qualified professionals with deep knowledge of international business and regulations, located in several jurisdictions and ready to advice customers with their risk assessment, management and preparation of deliverables and documentation in connection to all the transfer pricing aspects of their enterprises.

Through its Transfer Pricing Advisory Services Unit, Melenco experts will assist you design, manage, document, review and defend your transfer pricing policies and internal procedures, making sure that these efforts are aligned with your operations and strategy, helping your business to achieve its potential.

Are you aware of the importance of understanding transfer pricing risk exposure and prioritizing efforts to mitigate it?

The Local Tax Authority in your country of residence might review and challenge your company’s intra-group activity, offshore structures and/or transactions. It is important for you to be ready for these challenges and prepare for a potential transfer pricing (TP) audit. Melenco can assist you by reviewing your company’s cross-border activity and assessing its overall TP exposure and help you to develop options for identifying, managing and mitigating TP risk.

The above can be done by conducting a factual review of your company’s material intra-group activity, corporate and commercial structure, cross-border transactions, operations and audit history, following a simple path, consisting in:

Identification of potential problematic areas
Analyzing the compliance with international documentation requirements
Designing an action plan for implementation and monitoring of remedial measures
Assisting with the creation of a TP audit defense file
Helping with the foundation of a solid TP compliant base for further planning and effective tax rate management

TP Audit and Compliance Checklist

As part of the current international environment, which is being heavily changed by the design and implementation of new standards of tax assessment as a consequence of the launch of the final reports on the Organization of Economic Cooperation and Development’s (OECD) Base Erosion and Profit Shifting (BEPS) Action Plan, Melenco strongly recommends you consider the following relevant aspects of your company’s business activity:

Identify all related party transactions entered into a specific fiscal year (FY); the exact value of the identified transactions and the related party (ies) that these transactions were entered with (i.e. the counter-party).
Understand the nature of each one of these related party transactions.
Reconcile the value of each related party transaction to the trial-balance (both prior and post audit adjustments).
Ensure that the identity of the counter-party and the value of the related party transactions are accurately stated in the audited financial statements and relevant tax returns.
Ensure that the nature of the related party transactions is accurately stated in the financial statements and relevant tax returns.
Ensure that the correct TP method is being used and identified for each related party transaction and correctly indicated in any relevant tax returns.
Ensure that financial information or statements made in audited financial statements (e.g. business segments presented) will not have implications for the TP analysis of your related party transactions.
Where the TP method used for a related party transaction has changed from the prior year, understand the rationale for said change and whether or not it is defendable.
Complete your TP documentation file for related party transactions over the documentation threshold.
Identify and indicate in the relevant tax returns in case that you have transactions with related parties located in tax havens.

Restructuring and M&A Activity

Melenco can help you with validation of M&A activity and corporate restructuring from a TP point of view, including but not limited to the following services:

Review and validate if the business reorganization meets the expected levels of substance and compliance with BEPS requirements.
Assessment of the ‘TP Business Purpose Test’ by reviewing that the reorganization has its rationale and is not intended to be implemented for TP purposes.
Identifying the transfer of valuable tangible and intangible assets and the existence of an arm’s length reward.
Verifying the alignment between functions, risks, assets, profits and tax burden of the parties involved before and after the business reorganization.

REACH OUT

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CONTACT INFORMATION

contact@melenco.com