Global Transfer Pricing Services

Transfer pricing is one of the most important issues that businesses  must pay attention to when investing in various parts of the world. Tax  laws and tax authority’s requirements on transfer pricing may differ from country to country. Knowing the details and trends of transfer pricing policies throughout the world will help businesses make appropriate and adequate preparations in ways that minimize tax risks in order to avoid double taxation as well as reduce compliance burden associated with transfer pricing. As OECD published its  final BEPS Action 13 report, countries around the world are starting to make laws based on the transfer pricing documentation suggested  in the action plan. Meanwhile, the tax authority of Taiwan has  published new amendments to the transfer pricing regulation, which  officially incorporates Base Erosion and Profit Shifting (BEPS) Action  13 into Taiwan’s 3-tier transfer pricing documentation framework. These movements require businesses to re-examine their global tax  management strategies on a group level, and begin preparing new  transfer pricing documents as part of the day-to-day operation. Making  the right preparations would help businesses manage taxation costs  more effectively on a global setting.

KPMG's global transfer pricing service draws on the expertise of  senior tax professionals, financial analysts and economists from a  network of independent member firms affiliated with KPMG. Together,  they provide professional transfer pricing services to customers  around the world in areas that are relevant to their business activities.  KPMG's global transfer pricing service team comprises nearly 1500  professionals from different locations and areas of expertise.

• Transfer pricing advisory
• Transfer pricing document preparation (master file, CbCR, and  transfer pricing report)
• Transfer pricing project review and advisory service  Global transfer pricing policy review and planning
• Transfer pricing consultation services for tax disputes
• Value chain assessment and the tax optimization analysis of business  model under global transfer pricing system
• Review and analyze intangible transactions and the reasonability of profit allocation among affiliated companies in accordance with the regulations stipulated in OECD Guideline and Taiwan transfer pricing regulations.
• In accordance with the updated transfer pricing regulations announced by the OECD or each jurisdiction, review related-party transactions, transfer pricing policies, and the functional and risk characterized position among affiliated companies to mitigate potential transfer pricing risks.
• Review group effective tax rate, profit allocation, transfer pricing policies, and functionally characterized position among each jurisdiction to reduce tax burden globally and provide an optimized global tax strategy.
• Utilize the digital tax technology to evaluate and detect the potential  tax risks which might be occurred among Master file, Country-by-  Country reporting, and transfer pricing report in order to deliver  effective tax risk control solutions.
• Based on the corporate organizational structure, review the current  transfer pricing transactions and profit allocation. Furthermore,  evaluate the custom duty, business tax, or related tax issues from  respective jurisdictions to analyze and provide the best investment  tax structure.
• Application for advance pricing agreement (APA) and Mutual Agreement Procedure (MAP)