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transfer pricing
Preparation for Transfer Pricing Analysis
Gather relevant financial and operational data for all related parties
Identify intercompany transactions and potential transfer pricing issues
Review existing transfer pricing policies and documentation
Functional Analysis
Identify functions performed, risks assumed, and assets utilized by each related party
Determine the value of contributions made by each related party
Evaluate comparability factors such as industry trends, economic conditions, and market competition
Transfer Pricing Method Selection
Choose an appropriate transfer pricing method based on the nature of the transaction
Consider factors such as availability of data, reliability of comparables, and level of complexity
Comparability Analysis
Identify comparable transactions and companies for benchmarking purposes
Analyze financial data and economic indicators to determine arm's length pricing
Adjust comparables for differences in functions, risks, and assets
Documentation and Reporting
Prepare transfer pricing documentation in accordance with local regulations
Include detailed analysis, calculations, and justifications for pricing decisions
Maintain records and update documentation on an annual basis
Compliance and Risk Management
Monitor changes in transfer pricing regulations and guidelines
Conduct regular reviews and audits to ensure compliance with transfer pricing rules
Develop strategies to mitigate transfer pricing risks and disputes with tax authorities
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