Topic collection
Controversy & certainty
Transfer pricing is a forecast that gets tested years later. This is the toolkit for defending it, and for buying certainty in advance.
Year-end adjustment
5 minAn adjustment made by the taxpayer before or at year end to bring a controlled outcome into the arm's length range.
Transfer pricing adjustment
5 minA change to taxable profit imposed by a tax authority, or made by a taxpayer, to reflect arm's length conditions.
Advance pricing agreement (APA)
5 minAn agreement with one or more tax authorities fixing the transfer pricing method for specified transactions over a future period.
Mutual agreement procedure (MAP)
5 minA treaty mechanism through which two tax authorities negotiate to resolve taxation not in accordance with the treaty, including double taxation from transfer pricing adjustments.
Business restructuring
6 minThe cross-border reallocation of functions, assets or risks between associated enterprises, and the compensation, if any, due for it.
Transfer pricing risk assessment
4 minA structured review identifying which controlled transactions are most likely to attract challenge and what the exposure would be.
Book a TP Health Check
Unsure how your transfer pricing would hold up?
A fixed-scope review of your intercompany pricing, documentation and audit exposure — scoped to your jurisdictions, delivered as a written risk memo. First response within one business day.