Design: Transfer pricing strategy, operating model, value chain analysis, high-level functional analysis, transfer pricing design papers, comparable analysis (benchmarking studies).
Document: Contemporaneous Transfer Pricing Documentation (Master File, Local File and Special Issue File), related party transaction disclosure forms (including CbC template), transaction based documentation, preparing/reviewing/amending inter-company legal agreements.
Defend: Preparation of supporting documents, collecting audit trail, negotiation with tax authority, tax audit defence, APAs, MAPs.
Risk assessment: Risk assessment and management, prudential reviews, compliance assessments, future measures to minimize the risk effectively.
Train: Transfer Pricing Risk Manual, hands-on training for day-to-day practitioners dealing with the companies’ in-house transfer pricing risk management (Transfer Pricing Risks Assessment and Control Tools/Software).
Translate: Reviewing/amending transfer pricing documentation to meet Chinese requirements, translating English version transfer pricing reports into Chinese and vice versa.
International tax consulting
Thin capitalization: Identification and avoidance of the thin capitalization issue, taxation on thin capitalization, cash pool, etc.
Profit repatriation planning: Royalty and service fee remittances, withholding taxes on royalties, interest and dividends.
Permanent establishment (PE): Identification and avoidance of the PE issue, taxation on PE.
Tax treaty and beneficial ownership: Resolution of tax treaty disputes; identification of beneficial ownership.
Customs valuation assistance: Integrating transfer pricing and customs valuation solutions, managing customs valuation and transfer pricing documentation,customs valuation and royalties.
VAT advisory services: VAT compliance, VAT refund advisory for export goods and services; VAT refund advisory on process materials, order/ process with imported materials, etc.
Equity transfers: Application for indirect transfer of the Chinese company’s equity (Circular 698), taxation on indirect transfer.