The transaction price (transfer pricing) at which companies transfer tangible/intangible assets or provide services to related parties located in different tax jurisdictions has a significant impact on the taxable income of those companies. Therefore, tax authorities are highly interested in the transaction price. Many countries have established a tax system related to transfer pricing (transfer pricing taxation) and require companies to comply with transfer pricing rules when conducting transactions subject to transfer pricing taxation.

However, transfer pricing taxation involves extremely complex rules which differ between countries. In addition, the details of the rules are reviewed frequently based on economic conditions and other circumstances. Furthermore, transfer pricing tax audits often take longer than other audits and the amount of adjustment and penalties tends to be high.

In order for companies to appropriately correspond to transfer pricing risks, it is necessary to accurately understand tax laws, regulations, and other rules both in their home country and countries involved in the transactions as well as develop and implement appropriate countermeasures.

Through transfer pricing services, we provide the following support by cooperating with member offices located in over 150 countries and regions aimed at minimizing clients' transfer pricing risks:

• Transfer pricing risk analysis
• Support for transfer pricing policy establishment
• Support for transfer pricing documentation
• Support for advance pricing agreement and mutual agreement procedure