Transfer Pricing

Transfer price planning possibilities still exist, and compliance is essential, despite obstacles including heightened regulatory scrutiny globally, the number and variety of intercompany transactions, and the general complexity of international legislation.
Transfer pricing is a little-known fact that affects both multinational corporations and small- to medium-sized companies operating domestically in the United States.

In addition to addressing tax responsibilities, a well-designed transfer pricing policy and implementation can also focus on unintended exposures, fines, and even reputational damage brought on by inadequate preparation and execution.

Is My Existing Transfer Pricing process and team working well?
Edgesys can assist you in evaluating the effectiveness of your current transfer pricing system. Our “check-up” looks at a number of potential problem areas, including:

• Team build, expertise and pricing
• Transfer pricing updates and compliance
• The application of US tax rules, such as foreign tax credits and Subpart F, arises from related transactions.
• Challenges with country transfer pricing protocols, compliance requirements and legal deadlines.
• Excessive Withholding Tax.
• Companies that have suffered losses (after the start-up stage).
• Remittance restrictions make it difficult to account for year-end transfer pricing adjustments.
• Uncertainty about which companies own intellectual property, take the risk, and add business value.
• Uncertainty regarding the amount and basis of intercompany service, technical support, or administrative fees.

How Edgesys Can Assist
Our transfer pricing team consists of an experienced team of international tax experts, auditors and economists. Whether your business needs guidance on transfer pricing policies, assistance with implementation, or just a quick check-up, the Edgesys team can help:

Transfer Price Planning
For start-ups and companies with transfer pricing policies, Edgesys offers:

• Team building
• Process and management
• Analysis and Documentation
• Legal and compliance process and procedures
• Service to conduct Background of the Companies and its Affiliated Enterprises
• Functional analysis to record the deployed functions, risks, and assets
• Industry Overview
• Conducting Tax responsibilities
• Evaluate systems and procedures
• Comparability and benchmarking research to demonstrate the arm’s length character of international transactions made between associated businesses.
• Representing before Transfer Pricing Authorities – These services include representation before the designated Transfer Pricing Officers/Assessing Officers for Transfer Pricing related matters.
  The scope of services provided also covers representation before higher authorities like Commissioner of Income Tax etc.
• Opportunities for the group’s taxation to be reduced
• Benchmarking assistance for clients in comparison to other companies in the same industry
• Inter-company agreement drafting and review of paperwork
• Risk Mitigation and Compliance
• To avoid financial and reputational risks, businesses can benefit from the following Edgesys services:
• Transfer pricing document review for US and foreign compliance purposes.
• Support for BEPS readiness assessment and country compliance support.
• Assistance to ensure pre-pricing agreements and mutual agreement procedures.
• Assessment and support for transfer pricing items in working papers.

Tax Authority Controversy
Unfortunately, in a changing regulatory environment, government tax authorities may question a company’s transfer pricing. In this case, Edgesys can help:

• Tax Audit Defence
• Litigation Assistance, Including Expert Representation
• Arbitration
• Negotiation Assistance with Competent Authorities