The laws surrounding transfer pricing are becoming complex as the tax affairs of multinational companies face greater scrutiny.

Our team advises clients with regards their transfer pricing matters on an end to end basis including designing of operating structures, determination of pricing policies, assistance with statutory compliances and assisting with defence before tax authorities.

How we help

When an international business grows or restructures, there is an opportunity to optimise your business and minimise your tax burdens by reviewing current processes. 

We can help to

  • Design your operating models
  • Design transfer pricing policies and inter-company pricing arrangements
  • Carry out transfer pricing health checks to identify risks as well as profit optimisation opportunities
  • Restructure your existing business model to build tax/ commercial efficiencies
  • Restructure your supply chain

We use local knowledge to prepare specific documentation to satisfy tax regulations. 

We can help with the preparation and maintenance of:

  • Transfer pricing defence documentation
  • Multi-jurisdictional documentation studies
  • Master file and Country-by-Country Reports

We assist in defending transfer pricing positions undertaken by taxpayers in audit situations as well as proactively. 

We can help:

  • Draft technically sound responses to queries raised by revenue authorities as well as representation on transfer pricing related matters
  • Proactive dispute resolution through the unilateral/ bi-lateral / multilateral Advance Pricing Arrangements route
  • Manage dispute resolution through the Mutual Agreement procedures process

Why Grant Thornton

A brighter tomorrow starts with a clear eye on the horizon and compass to guide you. Which is why we match proactive insights to practical applications - all aimed at bringing you the best solutions. 

Case study

An efficiently designed transfer pricing model based on data

A multinational technology start-up was able to drive efficiency through changing their operating model, addressing risks in their transfer pricing model, relook their long-term pricing structure.

Case study

Refined pricing arrangements to support transfer pricing defense

A large technology company refined their arm’s length pricing arrangements to address operating losses. This also enabled the individual members to have a more robust transfer pricing defense in their respective jurisdiction.