TAX ADVISORY
Transfer Pricing
Systematic management of the tax risks
in your cross-border transactions.
We closely analyze the transaction structures and pricing policies with your foreign related
parties, and review the appropriateness of your transfer prices under the arm's length
principle — systematically managing your company's international tax risk.
SERVICE OVERVIEW
Sound transfer pricing starts with understanding transaction structures
and a rigorous arm's length analysis.
Companies transacting with overseas affiliates in goods, services, intangible assets, funding, and other areas must set their transaction prices in line with the arm's length price that would apply between independent enterprises, and manage the related tax risk accordingly.
It is essential to comprehensively analyze the functions and risks of the parties involved, the assets used, and the industry environment.
VITAL TAX takes the time to understand your company's global business structure and its transactions with foreign related parties, systematically analyzing arm's length pricing methods and comparability factors — to support the development of a well-reasoned transfer pricing policy and the management of international tax risk.
Service
Transfer Pricing
Category
Tax Advisory
For
Domestic Companies · Foreign-Invested Companies
Scope
Arm's Length Price Analysis · Policy Development · Documentation · International Tax
KEY SERVICES
Key Services
01
Transfer Pricing Policy Review
We analyze your transaction structures and existing pricing policies with foreign related parties, and review the appropriateness of your transfer prices — and any potential tax risk — under the arm's length principle.
02
Arm's Length Price Analysis
We analyze the functions, risks, and assets of the parties involved, along with comparability factors, and apply the appropriate arm's length pricing method to determine a well-reasoned arm's length range.
03
Transfer Pricing Documentation
We systematically analyze your foreign related-party transactions and transfer pricing policy to support related documentation requirements, including the Integrated Report of International Transaction Information.
04
International Tax Risk Response
We review transfer pricing-related tax issues and the tax authorities' requests for documents and explanations, and support your response to the tax risks arising from international transactions.
PROCESS
Our Process
01
Understanding the Transaction Structure
We assess your company's global business structure, its foreign related parties, and key international transactions, to define the scope of the transfer pricing review.
02
Functional & Risk Analysis
We analyze the functions performed and risks assumed by each party, along with the assets used and transaction terms, to identify their economic characteristics.
03
Arm's Length Price Analysis
We select the appropriate arm's length pricing method and analyze comparable transactions or companies to review the appropriateness of the arm's length price.
04
Policy Development & Post-Review Management
Based on the analysis, we propose a well-reasoned transfer pricing policy and documentation approach, and provide ongoing support for managing the related international tax risk.