Transfer Pricing documentation is an effective risk administration tool.
The laws surrounding transfer pricing are becoming ever more complex, as tax affairs of multinational companies are facing scrutiny from media, regulators, and the public. Well-run businesses need to consider this new emphasis on compliance and audit activity. Through our international organisation of member firms, we can help you understand these ever-more complex issues as your business continues its journey to growth. Although these laws may share common features across various countries, the interpretations can differ from one country to another.
We, at Grant Thornton Singapore, have an experienced team that assist tax payers across all aspects of their transfer pricing needs right from advising on design of operating models/ pricing arrangements to substantiating transfer pricing arrangements through robust documentation to assistance with dispute resolution matters on transfer pricing arrangements.
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Transfer pricing advisory
The growth or restructuring of a company doing business internationally provides an opportunity to review transfer pricing and tax planning to minimise tax burdens. Our assistance on advisory matters include, inter-alia, the following:
- Assistance in setting up business/operational models
- Restructuring of existing business model to build tax/ commercial efficiencies
- Assistance in designing transfer pricing policies and pricing arrangements
- Assistance with supply chain restructuring
Transfer pricing documentation
We use local knowledge to prepare specific documentation to satisfy tax regulations. Our assistance with documentation matters include:
- Assistance with preparation of transfer pricing defence documentation
- Assistance with preparation of Multi-jurisdictional documentation studies
- Assistance with Master file and Country-by-Country Reports
Transfer pricing dispute resolution
We assist in defending transfer pricing positions undertaken by taxpayers in audit situations as well as proactively. Our assistance on dispute resolution matters include:
- Assisting in drafting responses to queries raised by Revenue authorities as well as representation on transfer pricing related matters
- Assisting proactive dispute resolution through the unilateral/ bi-lateral / multilateral APA route
- Assisting dispute resolution through the MAP process
International transfer pricing guide
- If you would like an overview of different transfer pricing rules and regulations in key countries and details on contacting Grant Thornton, view our 2018 international transfer pricing guide.
- If you have any questions or would like to find out more about how we can help, contact Munjal Almoula, who leads this area of the business.
Client challenge: Prolonged operating losses and restructuring
Despite being in a booming industry, our Client incurred multiple years of operating losses with significant related party transactions.
Following an acquisition by an international technology firm in USA, the volume and complexity of cross-country recharges relating to intercompany loans, intangibles and intra-group services also increased.
As a result, the above gave rise to a need for the Group to review the relevance of their existing TP policies and refine the same to better fit today’s TP compliance landscape.
The Group was able to establish precise arm’s length pricing arrangements for their individual transactions enabling the individual members to have a more robust transfer pricing defense in their respective jurisdiction.