Transfer Pricing Risk Analysis

Based on recommendations by the Organization for Economic Cooperation and Development's (OECD) Base Erosion and Profit Shifting (BEPS) project, corporate groups above a certain size are required to prepare and submit a country-by-country report ("CbC report"). The information submitted are provided to the relevant tax authorities through automatic exchange of information based on tax treaties and other agreements. These exchange is intended to enable tax authorities in each country to briefly analyze tax risks of corporate groups based on the information obtained and to efficiently concentrate their limited resources on transactions with high transfer pricing tax risk.

As tax authorities select transactions subject to tax audit based on risk analysis, companies are required to identify high-risk items before tax authorities and take the necessary action to efficiently reduce transfer pricing correction risk.

Through transfer pricing risk analysis, we perform the following processes to analyze transfer pricing risk of corporate groups and provide information useful for the development of plans to address transfer pricing risk.
In addition to transfer pricing risk analysis, we provide support for the development of a transfer pricing policy and transfer pricing documentation.

Present state analysis
Confirmation of income distribution
Transfer pricing risk analysis

We are also available to provide the analysis of CbC report using BDO International's transfer pricing risk analysis tool. Please consider using our service to assess tax risk prior to the submission of a CbC report.