Transfer pricing

A well-conceived transfer pricing policy provides non-aggressive tax cost control opportunities whilst ensuring compliance across the global value chain.

Transfer pricing is governed by an established set of guidelines, legislation and best practice.   Through collaboration with member firms of the Moore Global Network we can work with you to ensure that your transfer pricing arrangements are robust and in accordance with OECD norms and those of overseas tax jurisdictions.  Correct arm’s length pricing to align profits with value creating activities not only ensures compliance with the law but provides a strong basis for management performance evaluation and the allocation of future resources.

Our services include:

  • Preparing and updating transfer pricing documentation, including OECD compliant local and master files
  • Benchmarking studies
  • Transfer pricing policy design and implementation
  • Drafting and executing intercompany agreements

In addition to the three-tier approach to transfer pricing, we also advise on the other elements of the OECD’s BEPS (base erosion and profit shifting) 15-point action plan and their impact on companies operating internationally. In particular:

  • Hybrid mismatch arrangements
  • Controlled foreign company rules
  • The corporate interest restriction
  • Permanent establishment status

Need some advice on transfer pricing? Get in touch with our lead expert, Ruth Brennan.