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At TPS, we can help you establish and implement optimized fiscal strategies through the review of your current Transfer Pricing (TP) policies, as well as, with the analysis of alternatives before getting involved in a related-party transaction. Well-defined TP policies ease the compliance with tax regulations in the different jurisdictions where the group operates, expediting the preparation process of the annual TP documentation and minimizing the risk of tax adjustments.
In this sense, at TPS, we assist with:
At TPS, we perform Value Chain Analyses (VCA) with the objective of aligning the Transfer Pricing policies with the economic value creation phases within the enterprise.
A VCA allocates the generated profit to each entity in accordance with their relative contributions to the overall value chain, analyzing the generated value in every jurisdiction. Our approach comprises the identification and valuation of the different steps within the goods production or service provision to determine the input of each party to the group’s value chain. We use that information to establish a market price for the transactions of the related companies, assuring it complies with the TP guidelines in each of the jurisdictions where the group has presence.
At TPS, we perform a deep and detailed analysis of your internal processes and review your TP policy. Our experience will allow you to adapt the policies in place to your current and future business plan and optimize your value chain. We recommend our Clients to perform this analysis in advance, in case there is a change in their business plan, or as part of a globalization process.
TPS offers advisory services in relation to the transfer pricing implications of the business, helping firms to deal efficiently with operational and financial changes. Whether due to an optimization of the value chain, integration of new businesses after M&A operations or changes in the market conditions, TPS has an extended experience with the analysis of the fiscal implications of business model restructuring or value-chain transformation (VCT).
A VCT can produce changes in the acquisition of raw materials, product design and services, or the value provided to your group, or clients. These can also affect the operations between business units and branches, requiring a reevaluation of the transfer pricing of goods, services, or intangible assets. Moreover, a VCT may derive in changes in the functions and responsibilities of the related party entities, affecting the cost, revenue and profit allocation between them.
Our services include:
At TPS we assist our clients in the evaluation of the impact of their business model restructuring processes and value chain transformation on their TP policies. With our experience and personalized attention, your firm can adapt to and thrive in an evolving business environment. We help ensure an efficient approach that is in accordance with the applicable tax regulations throughout all the steps of the process.
Given the increasing complexity of the environment and of tax regulations, business decisions need to be swift and coordinated. With that in mind, TPS offers to draft a Transfer Pricing Manual to guide the internal transfer pricing policy setting processes between related entities.
The elaboration of a Manual is based on a thorough analysis of the different alternatives that are available to the specific circumstances of a multinational group or related entity, with the objective of facilitating the definition of intra-group policies, based on the foreseen or foreseeable functional and risk profiles of the parties involved.
As such, it is designed and custom-tailored for each Client. In addition to facilitating and speeding up the transfer pricing policy definition at the Group/entity, a Transfer Pricing Manual also provides comfort to new investors, especially in financing rounds, or processes of mergers and acquisitions, establishing a solid basis for harmonization and tax compliance.
At TPS, we offer Operational Transfer Pricing (OTP) to guarantee the successful and practical implementation of your TP policy in organizational processes. Our focus ensures that the criteria established in your policy is reflected in the prices and registered in the tax declarations.
Our OTP service aligns the business plan with the TP policies, covering key aspects such as intragroup contracts, processes for calculating group billing, billing, financial reports, computerized systems and tax declarations. We establish procedures to monitor transfer pricing, which is a key phase to manage risk. This includes assuring that the results of the different groups of the firm are aligned with the Arm’s Length Principle in all the jurisdictions, as well as, identifying internal and external changes that require adjusting the TP policies.
Engage TPS for an effective implementation of your TP policy in your organization, with the guarantee that we will comply with the regulations and the optimization of your related party transactions.
