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DUBAI | ABU DHABI | RAS AL KHAIMAH
Transfer Pricing Advisory Services
In today's fast-paced transfer pricing environment, it has become crucial to have a strong approach for managing transfer pricing opportunities, compliance, and risks. The Organization for Economic Cooperation and Development's (OECD) Base Erosion and Profit Shifting (BEPS) Action Plans have put a major emphasis on transfer pricing, especially with the introduction of detailed transfer pricing regulations in the Kingdom of Saudi Arabia and Egypt.
Furthermore, groups with their headquarters in the region need to stay updated on the rapidly changing transfer pricing landscape in other jurisdictions where they have business entities, especially in light of the emerging Country by Country reporting and notification requirements as countries join and implement their commitment to the BEPS Inclusive Framework.
The evolving regulatory environment created by the BEPS initiative presents both opportunities and risks.
p>With a wide-ranging global network of leading transfer pricing professionals, BOT-APT Consultants is in a unique position to advise multinational companies on building, optimizing, monitoring, and defending their transfer pricing policies in a "post-BEPS" world.
We assist multinational enterprises (MNEs) in mitigating their transfer pricing risks, improving their transfer pricing documentation, and obtaining stronger confidence in their tax and transfer pricing positions in accordance with globally recognized transfer pricing standards and local regulations. It's important to note that not all intra-group transactions are intended to evade tax payments.
We aid clients in the formulation and execution of transfer pricing policies for their current and future intercompany dealings. We also help in creating a record of policies and their results, which not only cater to business and commercial goals but also diminish the likelihood of tax authorities imposing revisions and fines during audits.
This includes:
- Designing the most appropriate transfer pricing methodology for intra-group transactions
- Conducting relevant benchmarking studies to determine arm's length pricing
- Drafting the transfer pricing policy document to document the pricing mechanism
- Reviewing inter-company agreements to ensure transfer pricing compliance
- Supporting clients in implementing their transfer pricing policies and conducting regular reviews to identify any gaps.
Developing a robust and comprehensive transfer pricing documentation is crucial for multinational companies to defend their transfer pricing practices in the event of a tax audit.
At BOT-APT, we assist our clients in meeting both local and global transfer pricing documentation requirements, including:
- Preparation of Local Transfer Pricing documentation or Local File in accordance with local transfer pricing laws, drawing from our extensive experience gained during Income Tax and Transfer Pricing Audits.
- Preparation of Master File in compliance with local transfer pricing regulations and aligned with the Organization for Economic Cooperation and Development (OECD) guidelines.
- Country-by-Country (CbC) reporting, including meeting notification requirements and evaluating the transfer pricing risk exposure for clients as a result of submitting such data to tax authorities in various jurisdictions where the multinational group operates
Our services are tailored to help clients achieve their business goals, providing guidance on specific questions and addressing concerns such as:
- Ensuring that transfer pricing policies are aligned with commercial objectives
- Reviewing current inter-company arrangements to determine opportunities for tax efficiencies to be incorporated into the documentation
- Transforming supply chains to ensure that transfer prices align with value creation
- Attributing profits to Permanent Establishments.