Transactions between related parties are valid as long as the transaction is conducted in accordance with the arm’s length principle. Therefore, it is important to plan and maintain the transactions in the arm’s length.
Additionally, OECD has declared to prevent and avoid any base erosion and profit shifting by aligning the transfer pricing with the value creation i.e. function performed, asset used, and risk assumed. In this era, therefore, transfer pricing structure should reflect how companies economically create value. The traditional structure which is only focusing on formal/legal structures may be at high risk and prone to further scrutiny from tax authorities.
Our services would make sure that the planned transfer pricing policies and structures applied by our clients fulfil the OECD recommendation and domestic regulation, therefore, further scrutiny and disputes with tax authority would be minimized, in case the policies and structures were conducted.