Transfer Pricing
Build a defensible approach to related-party transactions across entities, functions and markets.
Transfer pricing is not only documentation. The pricing policy should reflect the commercial reality before the transaction is booked.
Related-Party Pricing
Related-party pricing should reflect what each entity actually does and contributes. Signum helps map the intercompany transactions, analyse the functions, assets and risks and translate the business reality into a supportable pricing and documentation framework.
Related-party transaction mapping
Identifying services, goods, financing, IP and other transactions between group entities.
Functional and risk analysis
Understanding which entity performs the functions, uses the assets and controls the risks.
Pricing-method selection
Selecting an appropriate transfer-pricing method for the transaction.
Benchmarking and economic analysis
Supporting the pricing position through relevant market and financial analysis.
Transfer-pricing documentation
Preparing local, master or transaction-specific documentation where required.
Audit, APA and dispute support
Supporting authority enquiries, advance-pricing discussions and dispute coordination where applicable.
Value to Price
Who performs the important activities?
Who owns or uses the assets supporting those activities?
Who actually controls and bears the relevant risks?
How should the transaction be remunerated?
How is the position documented and monitored?
Chinese related-party transactions should follow the arm's-length principle and be supported by analysis and documentation appropriate to the company and transaction profile.
Documentation requirements depend on the company's transactions and circumstances.
Identify the entities, transactions and value flows.
Assess functions, assets, risks and economic contribution.
Select and apply the appropriate pricing methodology.
Prepare evidence and maintain consistency between policy and actual transactions.
Reviewing Intercompany Transactions?
Align the policy, business reality and supporting evidence across the relevant group entities.
Initial consultation · No commitment required