Search
Explore our services, insights and latest news.
Transfer Pricing
At PHC Advisory we support Clients in preparing supporting transfer pricing documentation.
Transfer pricing is a cornerstone of international taxation and requires multinational groups to price their intercompany transactions in accordance with the arm’s length principle. Related‑party transactions must be priced according to conditions and contractual terms that independent third-party enterprises would agree to under comparable circumstances. Transfer pricing policies shall be defensible in the event of tax authority challenge using robust supporting documentation. Non‑compliant transfer pricing practices can trigger substantial tax reassessments, interest charges, penalties, double taxation risks, and disrupt dividend repatriation for foreign invested subsidiaries operating across China, Vietnam, India, Italy and the UAE.
Services
Contemporaneous documentation
Contemporaneous documentation refers to transfer pricing supporting records such as the master file, the local file, and the country‑by‑country report, required by tax authorities across most of our operating jurisdictions. The content includes entity overview profiles, related‑party relationship disclosures, full intercompany transaction details, functional, assets, and risk analysis, and descriptions of profit allocation methodologies. Timely, complete, internally consistent file maintenance is critical. Tax bureaus routinely request these materials during inspections. Missing, incomplete, or backdated records expose businesses to penalties and forced transfer pricing adjustments.
At PHC Advisory we support Clients by preparing, reviewing, updating and archiving compliant contemporaneous documentation on an ongoing basis. We align deliverables both with local statutory requirements and group‑wide transfer‑pricing policies, ensuring full traceability and audit readiness across all operating jurisdictions.f
Benchmarking analysis
Benchmarking analysis is the core transfer pricing compliance procedure aimed at assessing and verifying the arm’s-length nature of intercompany transactions. It involves screening and comparing comparable independent market transactions, analyzing industry profit ranges, and testing the rationality of related-party pricing policies. Unreasonable pricing without valid benchmark support will trigger tax authority challenges and profit adjustments.
At PHC Advisory we assist Clients in conducting professional industry benchmarking analysis, screen qualified comparable data and generate arm’s length verification reports to support intercompany pricing policies and reduce transfer pricing audit exposure.
Transfer pricing adjustments
Transfer pricing adjustments cover proactive and remedial profit adjustments for intercompany transactions that fall outside arm’s length range, applicable to entities operating in China, India, Vietnam, the UAE and Italy. This includes year-end self-adjustment of unreasonable profit margins, rectification of non-compliant transaction pricing, and coordination of corresponding tax adjustments to avoid double taxation. Improper or unadjusted abnormal profits will lead to tax supplements, late fees and regulatory penalties.
At PHC Advisory we support Clients in identifying transfer pricing discrepancies, execute compliant profit and tax adjustments, and arrange supporting filings to resolve pricing non-compliance risks and ensure tax consistency across jurisdictions.
Why PHC Advisory for Transfer Pricing?
At PHC Advisory we support Clients in preparing supporting transfer pricing documentation including master files, local files, and country‑by‑country reports. We deliver rigorous benchmarking studies drawing on recognized commercial databases, defend adopted pricing policies during transfer pricing audits, and execute compliant transfer‑pricing adjustments where required, bridging local country tax requirements with group level transfer pricing policies.
Who We Serve
- Multinational groups
- Foreign-invested subsidiaries
- Group tax directors
- Group CFOs and finance directors
- Mid-market groups with related-party transactions
- Private equity-backed groups
FAQ's
Related-party transactions must be priced according to the conditions and contractual terms that independent third-party enterprises would agree to under comparable circumstances, supported by robust documentation.
