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Transfer Pricing and tax: a critical contentious issue
On a global business scale, transfer pricing is one of the most contentious issues. No matter which industry you operate in or the size of your organization, it is critical to plan international transactions cautiously and to work according to the existing framework.
Your working payment plan should anticipate future changes in tax policies that may impact business activities and take local specificities into account.
Transfer pricing services determine the exact costs for another division of one company to deliver comparable services and goods. It is essential to establish those prices according to the price on the local market of similar services or products. Researches, patents, trademarks, or other intellectual property rights can also benefit from transfer pricing.
Transfer pricing enables Multinational Corporations to allocate and segregate their earnings from one subsidiary to another.
Since Transfer Pricing can be misused and manipulated for tax fraud, the application of international transfer pricing is regulated strictly as the transfer pricing mechanism can be a way to shift tax liabilities to low-cost jurisdictions.
Our firm delivers tailor-made and optimized solutions from planning to compliance and advisory services that will enable your organization to thrive in a complex environment and to adapt the right strategy.
Country By Country Reporting (CbCR) is a part of the OECD Base Erosion and Profit Shifting (BEPS) Action Plan 13. Large Multinationals have to prepare and share a CbC reportable template with tax authorities in the country where they have a taxable presence.
We deliver a CBC report that contains critical information on performance, owned assets, profit, Revenue, employed talent, paid taxes, capital structure, or retained earnings.
We also provide a Master File that will give an overview of the business’ global operations and related policies on the intra-company transaction.
Finally, we create a local file that will deliver a functional and economic analysis of international transactions undertaken by the local entity.
In a nutshell, UJA ensures the delivery of the following services:
