Advance Pricing Agreement Pwc

As a team, we are integrated into PwC`s global transfer pricing network, enabling us to build on the expertise of our colleagues in America, Europe and Asia and support your projects around the world. We use special TP software in our work and we provide IT tools for our customers to improve their internal TP capabilities. Transfer pricing management, in accordance with the principles of “weapons length”, is becoming more important in the current business scenario, which, due to the progress of globalization processes, implies a corresponding increase in intragroup business transactions. Helps with the analysis of transfer prices for financial transactions. We support our clients in their negotiations with the tax authorities and, when the client goes through a TP review, we support them during the review and, if that happens, in a preliminary and procedural phase. We focus in particular on “lead” products, such as pre-price agreements and TP models and policies, as they help our clients proactively address potential TP challenges, which is particularly relevant in today`s economic and fiscal environment. Help verify the consistency of your business model with your Intercompany pricing system in order to identify and reduce the potential risks associated with your transfer pricing policy, respecting an approach based on current international developments. Our team consists of more than 30 employees and includes experienced TP generalists, industry experts and specialists (such as financial transactions, commodity markets and IP transactions), as well as specialists in TP data analysis and visualization. Our executives work with Russian lawmakers and the tax administration to support our clients and advance the transfer pricing agenda.

Download our Transfer Pricing Flyer for details Shows knowledge about transfer pricing concepts, including intellectual property transfer, physical property and other financial transactions. help develop, formalize and implement transfer pricing policies. assistance to procedures as part of the mutual agreement for the settlement of international transfer pricing disputes. To assist in the development of a group-wide set of transfer pricing documents, based on a coordinated comprehensive approach that also meets local needs while maintaining efficiency from a cost management perspective. A career in transfer pricing gives you the opportunity to help our clients develop compliant and tax-efficient structures that will help them advance their business goals. They focus on all aspects of documentation planning, dispute resolution and pre-price agreements. Our team is responsible for all aspects of intercompany pricing agreements between related companies, including intellectual property transfers, in-kind transfers, services and credits, and other financing transactions. Two years ago, Hong Kong`s transfer pricing regime (“TP”) became stricter with the adoption of the 2018 Regulation (“BEPS and TP” of the Inland Revenue (Amendment) (No. 6).

In accordance with the provisions of the BEPS and TP Regulations, the Department of Internal Revenue (IRD) is authorized to impose TP adjustments for revenues or expenses resulting from non-arm length transactions between associates with a potential tax advantage in Hong Kong. Tax payers can expect a penalty up to the amount of the tax that is underestimated. We assist Russian and foreign companies in communicating with the Russian authorities regarding complex regulatory issues and TP audits (including assistance with preliminary communication with tax authorities and tax disputes in the area of TP).