Global Transfer Pricing Solutions
70% Increase in Cross-Border Disputes
Since 2020
Modern Transfer Pricing Challenges
Key Issues
- Increasing tax authority scrutiny
- Complex intercompany transactions
- Digital economy taxation
- BEPS 2.0 compliance
Global Impact
- 150+ Countries with TP regulations
- 40% Tax audit adjustments
- $300B Annual disputes
1
Documentation
Master file & Local file preparation
2
Analysis
Arm's length price determination
3
Reporting
Country-by-country disclosures
Our Expertise
- ▸ Comparable Uncontrolled Price Method
- ▸ Transactional Net Margin Analysis
- ▸ Profit Split Arrangements
- ▸ Advance Pricing Agreements
India Focus
- ✓ Safe Harbour Rules
- ✓ 3-tier Documentation
- ✓ Range Concept Application
- ✓ APA/MAP Support
Recent Engagements
Tech Giant Restructuring
$150M dispute resolution through bilateral APA
Pharma IP Valuation
Intangibles pricing for 25 jurisdictions