Toolbox

 

Tools Developed From Experience

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Preparing multiple transfer pricing documentation reports.

 

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Designing and developing transfer pricing methods under various situations.

 

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Advising on the smooth transition from one transfer pricing method to another.

 

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Defending various transfer pricing policies to tax authorities.

 

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Preparation of expert reports for transfer pricing judicial requirements.

 

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Benchmarking and valuing multiple transaction types.

 

Risk Assessment Tool

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Purpose of the Risk Assessment Tool

The Risk Detector tool is a series of 33 Yes/No questions for your self-assessment of your transfer pricing risk. This tool identifies areas where transfer pricing policies can be strengthened.

 

 

Measured Risk Indicators

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Audit

This is the risk of being selected for audit as well as the risk of receiving a more extensive audit when selected for an audit by a tax authority.

 

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Documentation

This is the risk the transfer pricing documentation to support and explain your transfer pricing policies is insufficient in today's transfer pricing regime.

 

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Methodology

This is the risk the current transfer pricing policy is producing pricing and terms for related party transactions that are not reflective of arm's length transactions.

 

 

 

 

 

 

Range Calculator Tool

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Purpose of the Range Calculator Tool

The Range Calculator tool calculate various range statistics that are used by various global tax authorities when determining the reasonableness of transfer pricing results. The tool allows for a list of up to 30 data points.

 

 

Calculated Ranges

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Statistical

This calculates the typical lower and upper quartile range (25th and 75th percentile).

 

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India

This calculates the 35th and 65th percentile that is referenced by Indian tax officials.

 

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United States

This calculates the lower and upper quartile statistics as defined by the US Internal Revenue Service.

 

 

 

 

 

 

 

Tools Under Development

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Profit Level Benchmarking

This will assist in the customization of profit benchmarks to a tested function.
 
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Global Service Fee Allocation

This tool assists in the allocation of fees for intra-group services.
 
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Functional and Risk and Industry Report Writer

Through a series of questions organized by key business segment and by legal entity, this tool will produce a report that forms the basis for establishing, implementing and supporting a multinational's transfer pricing policies.
 

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