Transfer pricing service

Transfer pricing service

For multinational companies, it is imperative to take appropriate countermeasures against transfer pricing which apply to both legal and actual operational conditions. It requires, however, strategic perspectives and a wide variety of information and experiences. Our services aim to support documentation of transfer pricing issues between Japan and overseas not only in terms of the tax code but also from diversified standpoints such as management.

Our transfer pricing services consist of the following two phases:

In this service, we provide documentation support required in the transfer pricing tax audits and assist advanced planning on how to deal with a request to disclose information of transfer pricing calculation at tax compliance.

Transfer pricing documentation (“TPD”)

Based on the analysis of detailed functions and risks of the parent company and its subsidiaries, we prepare the TPD to effectively defend against tax audits.

Advisory agreement

Verifying the TPD and the contract documents with the related companies periodically, we mitigate the transfer pricing risks.

Transfer pricing documentation (“TPD”)

In this service, we provide documentation support required in the transfer pricing tax audits and assist advanced planning on how to deal with a request to disclose information of transfer pricing calculation at tax compliance.

TPD project scope and procedure

1. Fact analysis

Analyze the basic facts of the target related companies profile, capital ties, outline of group network, organization structure, profits and losses of group companies and outline of your business field.

2. Determine business conditions among the related companies

Determine the form, flow, value of business among the related companies as well as their pricing strategy and price negotiation process.

3. Function/Risk analysis

Analyze function and risk of the significant related companies with target transactions.

4. Economic analysis

Based on the above results, we shape a fair transfer pricing method for the target transaction, select comparables and analyze the calculation of profit ratio.

5. Documentation

Putting analyses down in writing, we assist in preparation to effectively defend against tax audits in Japan.

Fee and time frame

Service type Complete commission type Partial commission type Hybrid type Profit ratio range calculation only
Work scope SHINSEI will take the initiative to perform overall tasks. SHINSEI will actively conduct economic analysis and TPD. SHINSEI will provide a custom template, schedule control and adequate advices. Using a database system, SHINSEI will figure out a profit ratio range according to the client’s instruction.
Responsi-bility Client SHINSEI Client SHINSEI Client SHINSEI Client SHINSEI
1 ×
2 ×
3 ×
4
5 ×
Fee Note#1-3 Please contact us Please contact us Please contact us Please contact us
Time required Approx. 4 months Approx. 4-8 months Approx. 4-12 months
Pros Less commitment Able to accumulate know-how at a certain level. Able to accumulate a good deal of know-how. Able to create documents at a reasonably low cost.
Cons Not able to accumulate know-how. Frequent commitment Lots of commitment Not able to work without an accumulation of know-how.

◯ proactive commitment △ limited commitment (provide info and contents check etc.)
× no commitment

Advisory service

It is vital to reiterate overall examination of business practice and contractual relationship within your group companies in order to maintain consistency with the transfer pricing policies. We conduct a review of your contracts from a perspective of transfer pricing at your request when adapting new requirements.

Terms of advisory

E-mail or Telephone consultation services

(Two hours per month as a rough standard, we can respond flexibly to your needs.) E-mail or verbal answer to queries based on the facts presented by clients.

  • Provide requested information
  • Give an explanation at the time of tax system reform and provide adequate advice for adjustment.
  • Other consultation services not involving particular projects such as TPD, formulation of transfer pricing policies and creation of written opinion etc.

Customer visit and meeting as needed basis

Contract review

  • Conduct a review of contracts among the related companies from a perspective of transfer pricing.

Update of TPD on an annual basis

  • Update financial statements in TPD annually.
    *TPD renewal is required triennially and at the time of substantial change of business.

Advisory fee

Please contact us

主な著書
海外資産の
税金のキホン
税務経理協会
2016年6月
法人税務
重要事例集
大蔵財務協会
2012年12月
図解 国際税務
早わかり
中経出版
2012年7月
法人税務
重要事例集
大蔵財務協会
2009年2月
税務便利辞典 税務研究会
2008年11月
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