Our teams include transfer pricing MAP specialists from both countries in dispute teamed with professionals who specialize in local country requirements for indirect taxes, taxes imposed by local or state/provincial jurisdictions, international tax and interest calculations for late payment that invariably affect the outcome. Deloitte takes an integrated approach to resolving transfer pricing disputes in the MAP process. Accordingly effective and efficient explanation of a business transfer pricing policies include early involvement of an experienced global team that has practical experience of all levels of the tax authority process, from proposed adjustments by field agents, through Advance Pricing Agreements, administrative appeals, litigation and the MAP process. Often it is the actions and responses in the initial stages of a tax authority enquiries or interviews that affect the course or outcome of a transfer pricing examination. This is powered by TP Search Smart technology, streamlining the gathering and processing of data and information needed to make informed business decisions.ĭispute resolution: Examination defense and mutual agreement procedure/competent authority To deliver transfer pricing documentation services Deloitte has a Global Dox Insight methodology. This centralised global approach facilitates uniformity of reporting and eliminates internal inconsistencies which can arise from multiple service providers, thereby making the process more effective, efficient and easier to explain to the relevant authorities. Deloitte provides practical solutions such as strategic approaches to transfer pricing documentation requirements, which help global businesses to achieve their operational and international tax objectives.ĭeloitte has a Global Transfer Pricing Center, that includes economists, tax professionals and MBAs who have on-the-ground international transfer pricing experience in Europe, the Americas or the Asia Pacific. This coupled with increased tax authority collaboration across borders presents both risks and opportunities. Multinational businesses are expanding the volume of related-party transactions and continuously improving their supply chains. This discussion looks at how companies can mitigate risks and enhance deal value from a transfer pricing perspective. Shell has a structured approach to transfer pricing.Transfer pricing advisory and documentation Transfer pricing is increasingly seen as one of the main tax risks and opportunities before, during and after the deal. The FO TP Team focuses on compliance, including the preparation of documents according to OECD recommendations and country regulations.

The Global TP Team provides support to Shell businesses, supports any engagement with tax authorities and provides guidance for projects. The responsibility for transfer pricing matters lies with Shell’s Global TP Team and Finance Operations (FO) TP Team. Shell has a structured approach to transfer pricing accountabilities and responsibilities. These methods are applied consistently across the Group. The guidelines outline transfer pricing methods that can be used to apply the arm’s length principle in practice. Shell also follows the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (OECD TP guidelines), as incorporated in applicable local tax laws. The arm’s length principle ensures that individual group members are taxed on their transactions with each other just as if they were comparable independent enterprises operating in open markets. Appropriately pricing and documenting your intercompany transactions to comply with various countries rules and legislation is imperative in managing tax risk. Shell applies the internationally recognised arm’s length principle where profits from the sale of goods or services are allocated to the countries where the relevant economic activity takes place and cannot be artificially taken somewhere else. Transfer pricing (TP) refers to the setting of prices for goods and services sold between related entities within a group.

Transfer pricing tax