Transfer Pricing

Strategising international Transfer Pricing

Globalisation has led to the international tax framework to become applicable in every country and Transfer Pricing (TP) is one of the key concepts. The focus towards tax on value creation under the OECD’s globally accepted Base Erosion & Profit Shifting (BEPS) concept has given Multi-national Enterprise (MNE) groups a unique set of challenges along with increasing volumes and a variety of daily operational transactions. In the midst of a continually evolving global regulatory landscape as well as increased pressure from national legal entities, Transfer Pricing becoming a critical issue for a lot of global businesses.

Transfer Pricing is the pricing offered by one member of the MNE group to another member outside the country for exchange of goods, services, financial transactions and other intangibles. Cross-border intra-group transactions have become the norm. With these transactions, taxpayers must comply with the various enhanced and ever-increasing regulations across jurisdictions, which is time-consuming and complex. It can also leave businesses with inadequate time and resources for strategic and commercial decisions. With Automatic Exchange of Information (AEOI) and Country-by-Country Reporting (CbCR), tax authorities across the globe are sharing and can plan to share information in real-time on cross-border related party transactions through Multilateral Agreements.

Transfer Pricing is a continuous task. Hence, businesses should apply a systematic approach for TP Risk Management and controls along with compliance obligations such as documentation, TP study (local file), master file, records, process, etc. We at MBG Corporate Services, have an in-depth understanding of the compliance requirements under KSA, UAE and other GCC TP, Country-by-Country Regulations and Tax Legislations and assist taxpayers in the filings and timely accurate compliances.

Our Transfer Pricing team along with tax advisors with our global experience can be your one-stop advisor for providing end-to-end robust and sustainable TP solutions. MBG Corporate Services supports you by outlining a clear Transfer Pricing strategy in line with regulatory expectations and then aligning it with your global business goals.

Our expert team can deliver vital advice on the Transfer Pricing model that resonates with your value chain through continuous financial analysis and timely interventions. We make sure to document all related party transactions to position your Transfer Pricing model to satisfy regulatory provisions. Our Transfer Pricing team and Tax Advisors can guide you through complicated areas of international tax and mitigate the risk of non-compliance.

Here are a few areas where you will require Transfer Pricing if you:
  • Need assistance in supporting your existing TP policies and in complying with documentation requirements
  • Need to implement new TP models driven by changes in the supply chain
  • Need to defend your transfer prices or need assistance in dispute resolution
  • Need to assess BEPS impact
  • Need to assess COVID-19 impact and build a robust TP defence
Our range of services include:
  • Conducting Transfer Pricing related due diligence and diagnostic reviews
  • Supporting TP Policies by preparing local files, master files and CbCR templates, as per KSA, UAE and other local GCC tax law requirements and BEPS guidance
  • Advising MNE groups on TP related business restructurings and Supply/Value Chain Transformations (VCTs)
  • Assisting in the implementation of TP models and provide tax authority litigation support and dispute resolution related services

What can we help you achieve?

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