1. Advise on Group Transfer Pricing Policy.

A Transfer price for intra-group transactions within the MNE can help create a value- addition based value transfer rather than the price always from the taxation impact perspective. Assigning the effective price, while moving along with goods and/or services within the intra group transactions will help in establishing a value based system which is justifiable and tax efficient.

2. Assistance in Preparation of Country By Country Reporting.

BEPS Action Plan 13 mandates all MNE’s to prepare Country by Country Report on aggregate data on the global allocation of income, profit, taxes paid and economic activity among tax jurisdictions in which it operates. This CbC report is shared with tax administrations in these jurisdictions, for use in high level transfer pricing and BEPS risk assessments.

We prepare the Transfer Pricing documentation Country by Country Report, which allows a multinational company to verify compliance with its Transfer Pricing obligations worldwide, taking into consideration the generation of value produced in each State. For this purpose, financial and accounting information of the corporate group must be submitted in all the countries where it has operations.

3. Assistance in Preparation of Transfer pricing Local File.

We prepare the Local Report or Transfer Pricing Technical Study that contains the relevant information to analyze the operations between a company and its related parties, for tax purposes, and/or transactions carried out with countries or territories of low or no taxation (or non- cooperating countries or territories), taking into consideration the formalities required by the tax regulations and the practice or casuistry of each country. Such information includes the financial data of the operations, a comparability analysis, and the selection and application of the transfer pricing method, according to the regulation of each country, in order to prove whether the transactions analyzed comply with the Arm’s Length principle.

4. Assistance in Preparation of Transfer pricing Master File.

We prepare the Transfer Pricing Master File, which must include standardized information corresponding to all the companies or entities that comprises the business group. In accordance with the Transfer Pricing Guidelines developed by the OECD (Organization for Economic Cooperation and Development), this Report must include the organizational structure of the business group, a description of the business or businesses, intangibles, and financial and tax positions, among others.

5. Preparation of Group/Standalone Transfer pricing Studies/Reports.

A detailed and systematic study of the group/standalone entity’s related party transactions (both local and international) is undertaken to understand, volume and complexity of transactions, right methodology for ascertaining the transfer price, compliance Arm-length principles and determine the best possible transfer price and suggest for primary and secondary adjustments in the Transfer price.

6. Advice and Technical Opinions on DTAA and CTA across the MENA region

Cross Border Transactions fall under the clear scope of DTAA and CTA, where beneficial guidance can be ascertained as an alternative to the local income tax/corporate tax law. DTAA and CTA’s enable business to undertake cross border transactions with more clarity and legal options for grievances. We offer advise and technical opinions with our team having deep understanding and experience of working with cross border transactions.