Transfer Pricing Support
As business becomes more global, transfer pricing is a management issue not only for large multinationals but also for mid-sized and smaller companies with overseas subsidiaries. Inadequate compliance can lead to substantial additional assessments and double taxation, raising tax risk significantly.
Companies that should pay particular attention
- Sales and purchases of goods between group companies
- Management, sales or technical support services between group companies
- Licence agreements for trademarks or technology between group companies
- Financial transactions between group companies (intercompany loans, guarantees and similar)
- Growing transaction volumes between group companies
What proper compliance achieves
Service menu
A full inventory of transactions with foreign related parties to identify where risk sits and how large it is, including a simplified review of pricing using existing data.
Support for preparing the Local File (LF) and Master File (MF), including functional and risk analysis, industry analysis and selection of comparable transactions. Engagements limited to specific analyses are also welcome.
Support in determining pricing methods and policy, and in building, reviewing and operating group-wide transfer pricing policy.
Support with preparing and filing applications, and with the authorities through pre-filing consultation, review and mutual agreement procedures, including liaison with overseas advisers.
Advance preparation, organising the required documentation, planning the response, and attending meetings with the authorities alongside you.
Decarbonisation & Sustainable Management Advisory
Environmental action has moved from being part of CSR to a management issue tied directly to corporate value and competitiveness.
Decarbonised management
An approach that reduces CO₂ emissions from business activities while sustaining growth: lower energy costs, greater trust from business partners, new commercial opportunities, and higher corporate value.
Sustainable management
Management aimed at long-term corporate value while balancing environmental, social and economic considerations, with emphasis on the three ESG perspectives: Environment, Social and Governance.
E
ENVIRONMENT
Environment
CO₂ emissions, resources and energy
S
SOCIAL
Social
Employees, business partners and local community
G
GOVERNANCE
Governance
Transparency and sound decision-making
Benefits for smaller companies
- Lower utility and fuel costs
- Stronger recruitment
- Better standing with banks and business partners
- Access to subsidies and support schemes
- Preparedness for future business risk
Common concerns we hear
Examples of support
* We do not handle work reserved for certified administrative procedures specialists (gyoseishoshi), such as preparing licence and permit applications. Where such work is required, we will introduce a partner firm.
Bookkeeping & Tax Return Services
For small and medium-sized businesses not subject to statutory audit (sole proprietors and companies), we support back-office work from day-to-day accounting through to tax filing.
For matters not listed above, please feel free to contact us. We will propose the support that best fits your situation.
Start with an informal conversation
We welcome enquiries on transfer pricing, decarbonisation and sustainable management, and bookkeeping and tax return services.