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Transfer Pricing

Transfer pricing has become one of the most important and complex tax issues, attracting significant scrutiny from tax authorities worldwide. As the global economy becomes more integrated, transactions involving goods, services, and intellectual property between companies within a single multinational enterprise (MNE) are increasing rapidly. Approximately 60% to 70% of all global trade occurs within these intra-group transactions, making transfer pricing an unavoidable issue that must be managed optimally. Transfer pricing is the process of setting prices for transactions between related entities, such as the sale of goods, services, or intellectual property between a head office and its subsidiaries.

Improper transfer pricing arrangements can not only trigger disputes with tax authorities but also lead to serious financial risks, such as double taxation (where the same profit is taxed in two or more different jurisdictions) and reputational risks that can significantly damage a company's image and business. Therefore, proactive and well-planned transfer pricing management is no longer just a legal obligation—it’s a strategic necessity to ensure business stability and sustainability.

In this dynamic global business landscape, transfer pricing is a crucial aspect that demands serious attention from every multinational company. Incorrect arrangements can lead to significant risks, from tax disputes to unexpected financial losses.

At TPC, we understand the complexities and challenges inherent in transfer pricing. Our team of experts has deep knowledge and extensive experience in helping clients manage risks, ensure compliance, and optimize their tax structures globally. We provide comprehensive solutions for your company's transfer pricing compliance.
Our Transfer Pricing Services
We offer a range of integrated transfer pricing services, designed to provide holistic solutions from planning and implementation to documentation.

1. Transfer Pricing Planning and Strategy
We work with you to design a solid transfer pricing strategy that aligns with your business model. This approach focuses not only on compliance but also on operational efficiency and tax burden optimization. We help you identify potential risks and build a robust framework for your intercompany transactions.

2. Transfer Pricing Implementation and Management, Business Restructuring, and Tax-Efficient Global Value Chains
We don't just plan; we guide you through the implementation of your transfer pricing strategy, including managing transfer pricing risks throughout the year. This service involves business restructuring and optimizing your Global Value Chain to ensure your business structure is tax efficient. We help integrate your transfer pricing strategy into your daily operations to ensure compliance with regulations and maximize legitimate tax benefits.

3. Transfer Pricing Documentation (TP Doc) and Advance Pricing Agreements (APA)
Comprehensive, in-depth, and accurate Transfer Pricing Documentation (TP Doc) is key to avoiding transfer pricing disputes with tax authorities. We help you prepare your transfer pricing documentation, including the Master File, Local File, and Country-by-Country Report.
To provide greater legal certainty, we also assist clients in applying for an Advance Pricing Agreement (APA). An APA is a proactive agreement between a taxpayer and tax authorities regarding the transfer pricing methodology to be applied in the future. Additionally, we provide services related to Mutually Agreed Procedures (MAP) to resolve international tax disputes, especially those concerning transfer pricing, between two or more countries.

4. Assistance with Transfer Pricing Tax Audits and Disputes
If your company faces a transfer pricing tax audit or a tax dispute, our team is ready to assist you. We provide expert representation by experienced transfer pricing professionals before tax authorities, formulating strong arguments and seeking favorable resolutions through negotiation or other dispute resolution processes such as tax objections, tax appeals, tax lawsuits, judicial reviews, and Mutually Agreed Procedures (MAP).

5. Transfer Pricing Training and Workshops
We believe a strong understanding of transfer pricing is crucial for every level of management. We offer specialized training programs tailored to your team's needs.

Training for Mid-Management: Designed for operational managers and finance teams directly responsible for intercompany transactions. This training focuses on the foundational principles of the arm's length concept, transfer pricing methods, and proper documentation and reporting procedures. The goal is to ensure day-to-day operational compliance and mitigate risks at the operational level.

Training for High-Level Management: Tailored for directors and executives who make strategic decisions. This training covers high-level issues such as global transfer pricing risk management, the implications of business restructuring, the impact of international regulatory changes (such as the BEPS 1.0 and BEPS 2.0 projects), and how transfer pricing can be part of a broader business strategy. The goal is to provide strategic insight to ensure top-level decision-making is both efficient and compliant.

We have provided extensive transfer pricing literature in Indonesia, including various articles, opinions, regulatory analysis, and reviews of "unique" transfer pricing dispute court decisions, which can be accessed here.

Why Choose Us?

In-depth Expertise: Our team consists of internationally certified professionals with a deep understanding of domestic and international tax regulations.

Continuous Partner Involvement: Every service we provide is directly supervised and reviewed by our transfer pricing partners. This involvement acts as the final safeguard to ensure the quality and accuracy of every deliverable, guaranteeing that you receive the best, most accurate, and reliable solution.

Customized Approach: Every company is unique. We design solutions tailored to your specific business needs and challenges.

Risk Mitigation: We not only help you comply with regulations but also protect your company from the financial and reputational risks that can arise from transfer pricing issues.

Don't let the complexities of transfer pricing hinder your business growth. Contact us today for a consultation and find out how we can help you manage your transfer pricing compliance effectively and efficiently.