International businesses have to make sure all related party dealings are arranged at arm’s length.
Transfer Pricing is a major topic for international businesses.
The level of tax transparency required by most countries must be met by master-file and local-file documentation reports as well as by Country-by-Country Reporting (CbCR) which disclose the group’s key figures and information
The ultimate allocation of taxable profits is with the creation of value, and hence diligent value chain analyses (VCA) are key to develop, manage and defend a company’s global profit attribution and tax set-up.
Only the translation of a company's business models into sound transfer pricing guidelines enables sustainable management and defence of tax and transfer pricing organisation from daily application to annual documentation.
Arm’s length conditions are, in most cases, discretionary. As a result, companies must understand what the arm’s length standards are to effectively assess and manage any related risks.