vanbain Transfer Pricing provides clients with the following global transfer pricing services:

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Strategic Advisory

We have extensive experience in providing strategic consulting advice to multinationals and small businesses. From start-ups to global listed entities we offer a full spectrum of consulting services.

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Transfer Pricing Policies

A transfer pricing policy sets out the Group (and/or local entity) 's intention of how intragroup transactions should be priced. Such policies generally would also include potential terms and conditions of such transactions and how they should be practically implemented. The support contained in transfer pricing policies would include the selection of transfer pricing methods and the application of that method including potential benchmarking studies and CUP support. ​Having a transfer pricing policy in place is important as it sets out the intent of the Group and specific local entities in relation to intragroup transactions. We assist client in preparing such policies and provide practical guidance for their implementation.

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Group Agreements

Having formal agreements setting out the application of transfer pricing policies between Group companies in relation to intragroup transactions is a vital part of a local entity's compliance requirements. ​Such agreements may be asked for by revenue authorities and form the basis of any defense/dispute. ​Such agreements also provide certainty to local entities forming part of a broader global Group. vanbain Transfer Pricing assists in preparing Group agreements.

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Benchmarking & CUP Studies

In order to either set transfer pricing policies or provide support for intragroup transactions, various transfer pricing methods may be utilised. In applying these methods, benchmarking studies or CUP support may be utilised. ​It is critically important that these studies or support are prepared with care as they are often the item of dispute by revenue authorities which can lead to significant assessments. Having access to a variety of third party databases we are able to offer clients a much broader set of options in relation to benchmarking studies and CUP support. ​We perform all benchmarking studies and CUP support within vanbain, ensuring quality and reliability of results.

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Transfer Pricing Compliance Documentation

Most countries today have some form of transfer pricing compliance documentation retention or submission requirements. ​These documentation requirements may include:

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- Non-OECD transfer pricing report

- OECD master file

- OECD local file

- OECD CbCR

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Which taxpayers are required to prepare such documentation is dependent on local and global legislation. Contact us for more information regarding your specific jurisdiction's requirements. ​The implications of not complying with such legislation includes tax return non-compliance (when required to be submitted with transfer pricing documentation), adjustments by local revenue authorities to taxable income of the local taxpayer, and resultant significant interest and penalties. vanbain assists clients globally with the preparation of all transfer pricing compliance documentation. ​Our wealth of experience ensures market leading services, timeous preparation of compliance documentation and value-adding annual strategic advice.

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Financial Transactions

Financial transactions are a broad type of intragroup transaction including loans, facilities, guarantees and any other transaction of a financial nature. ​Intragroup financial transactions are one of the most complicated types of intragroup transactions and therefore are often the most scrutinised by revenue authorities. In addition, they almost always have other tax and commercial implications that need to be considered and documented. We offer the following services in relation to cross border financial transactions between Group entities:

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• Debt capacity analysis

• Interest rate analysis 

• Thin capitalisation reports

• Reserve bank assistance

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Controversy and ADR

Controversy and alternate dispute resolution (ADR) occur when a revenue authority challenges an aspect of a taxpayer's annual tax return or transfer pricing practices generally. ​Countries have globally faced increasing economic and political pressures resulting in the tightening of tax scrutiny including transfer pricing audits. ​Taxpayers globally are also under pressure, including political pressure, to not only do what is required of them in law, but to do the perceived "right thing" in relation to tax paid in each country. ​Adding COVID to the mix has only added to these pressures which will no doubt result in a significant increase in transfer pricing controversy.

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How can we assist?

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- Initial strategic discussions

- Initial revenue authority responses

- Collaboration with our/your legal partners

- Assistance with preparation and collection of data

- Correspondence with revenue authority

- Negotiation with revenue authority on your behalf

- Preparation of benchmarking studies

- Preparation of CUP support

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