Transfer Pricing

On 10 December 2018, the Kingdom of Saudi Arabia (KSA) General Authority of Zakat and Tax (GAZT) released Transfer Pricing regulations. The rising volume and variety of intercompany transactions and transfer pricing regulations

On 10 December 2018, the Kingdom of Saudi Arabia (KSA) General Authority of Zakat and Tax (GAZT) released Transfer Pricing regulations. The rising volume and variety of intercompany transactions and transfer pricing regulations, accompanied by increased enforcement activities worldwide have made transfer pricing a leading risk management issue for global businesses. Transfer pricing refers to pricing arrangements in relation to all aspects of intra-group transactions occurring between related business entities. These include transfers of tangible goods, provision of services, transfers of intellectual property, issuance of loans and other financing transactions.

The stakes are high:

The factors driving intensified scrutiny of transfer pricing arrangements are beyond the control of most companies, but the risks to your organization are very real. They include:

  • Very large local tax reassessments — with significant penalties and interest on overdue tax – and double taxation on income when relief under tax treaties is not available;
  • Uncertainty about your worldwide tax burden, and expensive, time-consuming conflicts with regulatory authorities;
  • Damage to reputation and corporate brand if seen as a bad corporate citizen.

How we can help you:

At ALTAPETE our transfer pricing professional’s help you build, manage, document, review and defend your transfer pricing policies and processes — aligning them with your business strategy. Our talented people work with you to build the proactive, pragmatic and integrated strategies that address the tax risks of today’s businesses and help your business achieve its potential.

  • Strategy and policy development
  • Governance optimization and decision making process to help:Reduce impact of year-end adjustments – Monitor transfer pricing footprint – Coordinate across organization
  • Controversy risk assessment, remediation or mitigation as a result of documentation requirements
  • Global transfer pricing controversy and risk management

Transfer Pricing Services:

ALTAPETE’S Transfer Pricing Services practice helps companies develop and implement economically supportable transfer prices, document policies and outcomes and respond to tax challenges. We can help companies manage their transfer pricing issues through such services as:

Planning: To assist in developing economically supportable transfer pricing policies and in executing forward-looking tax planning.

Implementation: To provide insightful advice on developing and implementing policies, procedures, controls and systems for setting, monitoring, and testing intercompany transactions.

Controversy: To help resolve transfer-pricing disputes through various services, including assistance with advance pricing agreements, competent negotiations, arbitration, and litigation support.

Compliance and Documentation: To help manage risk within the current environment of detailed transfer pricing regulations, strict documentation requirements, sophisticated audit practices, and significant penalties for noncompliance with an objective point-of-view.