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Seth Sahil
Seth Sahil Director, Transfer Pricing

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Transfer Pricing

With rapid globalization and close integration of world economies, there has been a quantum leap in the volume, magnitude and complexity of intercompany transactions taking place across different countries. As a result, Transfer Pricing provisions, standards and compliance obligations have also become more detailed as well as stringent in the majority of the tax jurisdictions.  

Thus, it has now become significantly crucial for companies to ensure that the prices of all their intercompany transactions duly comply with the arm’s length principle as prescribed under their respective local laws to ensure adequate compliance. Many landmark Transfer Pricing rulings on several complex topics and issues have also been pronounced over the past years, as a result of increased Transfer Pricing audits. 

 

How can PKF-CAP help 

At PKF-CAP, we have a dedicated team of Transfer Pricing (TP) experts and specialists who have rich and significant TP experience spread across different industries and sectors and can provide all the necessary assistance and support to you in terms of TP compliance, advisory, dispute prevention and dispute resolution, in accordance with the Singapore and Asia-Pacific rules and regulations as well as the global TP principles and standards prescribed by the OECD.  

Some of our key TP service offerings include the following: 

 

  • Undertaking detailed diagnostic reviews of existing intercompany transactions, business models and TP policies, highlighting the potential red flags and suggesting the appropriate arm’s length prices in accordance with the local regulations; 

 

  • Providing assistance towards conducting robust economic (including benchmarking analyses) for intercompany transactions pertaining to services, manufacturing, distribution, royalty fee, license fee, trademark fee, franchise fee, intercompany loans, corporate guarantees etc; 

 

  • Assistance towards preparation of TP Documentation, TP Memo and review of Group TP Master File or policy document; 

 

  • Assistance in conducting value chain analysis, alignment and transformation; 

 

  • TP Advisory covering aspects like planning benchmarking analyses, TP issues related to Permanent Establishment, Intangibles, business restructurings etc; and  

 

  • Assistance in TP audits, Advance Pricing Agreement and Mutual Agreement Procedure