• Transfer Pricing

Transfer Pricing

When Obligations turn Opportunities

The Base Erosion and Profit Shifting (BEPS) Actions, issued by the OECD in October 2015, have prompted Hong Kong to issue Hong Kong's transfer pricing regulations in July 2018. Such legislation ensures multinational profits are taxed where the value is created. Additionally, China's transfer pricing regime has also increased its regulatory strength and complexity. Failing to manage transfer pricing effectively can lead to (i) tax audits and reassessments, with the potential penalties, (ii) double taxation in multiple jurisdictions, (iii) costly and time-consuming dispute with tax authorities, and (iv) reputational damage to brand and business.

To effectively manage your transfer pricing compliance effort, we will help you to articulate the policies and information required for local documentation as well as a cost-effective module to cover your global businesses for Master file/Local file compliance. In the midst of such complex obligations hides various opportunities to optimise profits, increase cash flows, and manage tax liabilities. With our diverse professional knowledge in a range of industries and global business segments, we deliver fresh thinking and robust transfer pricing solutions as your businesses grow while the market conditions evolve.

As part of the BDO Global Transfer Pricing network, our practice assists multinational companies in managing transfer pricing risks, handling cross-border compliance issues while identifying planning opportunities. Our professionals work to develop transfer pricing policies that are defensible, flexible, and congruent with your company's overall business organisation and global tax objectives.

Our team is comprised of economists, tax practitioners, and financial analysts. We advise multinational businesses on transfer pricing issues, including:

  • Global value chain analysis and TP advisory
  • Transfer pricing compliance and documentation (Country-by-Country reporting, Master file and Local file)
  • Global transfer pricing advisory
  • Intercompany pricing policy health-check
  • Intangible valuation in intercompany transaction
  • Transfer pricing dispute resolution
  • IPO transfer pricing support


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