Transfer Pricing

Transfer pricing is the pricing of goods, services and intangibles between related parties.

Introduction to Transfer Pricing 

  • Overview of Transfer Pricing
  • The Arm’s Length Principle
  • Transfer Pricing Documentation

Transfer Pricing Administration

  • Reporting of Related Party Transactions
  • Transfer Pricing Consultation 
  • Surcharge for Non-Compliance with Arm's Length Principle
  • Penalties for Non-Compliance with Transfer Pricing Documentation Requirements
  • Overview of Mutual Agreement Procedures (MAPs)
  • Overview of Advance Pricing Arrangements (APAs)

Other Issues

  • Applying The Arm’s Length Principle to Related Party Services
  • Applying the Arm’s Length Principle to Related Party Loans
  • Attribution of Profits to Permanent Establishments (PEs)  

Country-by Country Reporting

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