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  • Transfer pricing planning and risk management

Transfer pricing planning and risk management

Your Concerns

  • Ensure pricing of your related party transactions adhere to the arm’s length principle.
  • Get assistance in navigating through the post BEPS, tax and transfer pricing landscape, specifically master file, local file and country-by-country reporting (“CbCR”)

How BDO Can Help

Businesses frequently look to change their business model to drive customer and shareholder value. Whether setting up in new markets, introducing central procurement, moving production to lower cost countries, relocating senior management or integrating acquisitions, we can help you to manage resulting transfer pricing risks and the group’s tax position in a sustainable way.

Some other key areas we typically look at in delivering our transfer pricing advisory and planning services are:

  • Potential exit charges, permanent establishment risks and the preservation of tax attributes (eg losses) on the movement of functions, assets and risks.
  • Identifying and addressing other tax risks including CFC issues, sales taxes and custom duties.
  • Managing the right level of substance taking into account commercial needs and tax risks.
  • Setting and defending an arm’s length transfer pricing policy with supporting documentation.
  • Helping you embed new policies and effect change.
  • Preparing Advanced Pricing Agreements (APAs).


Our experienced global team comes from a diverse range of technical and professional backgrounds. The team has technical transfer pricing expertise in tax, law, economics, finance and has developed this expertise in a range of professional settings that include professional services, industry and revenue authorities around the world. This strength and diversity of knowledge creates an environment where our team is able to bring fresh thinking and a varied perspective to every transfer pricing project enabling us to deliver creative, robust transfer pricing solutions.