Transfer pricing applies to businesses that transact with associated enterprises, especially in cross-border group structures.
It may cover international transactions and specified domestic transactions, where applicable. Common related-party transactions include management fees, technical service charges, royalty payments, cost sharing, reimbursements, inter-company loans, product sales, support services, software services, marketing support, back-office services, and shared resources.
Management fees and royalties
Software and support services
Inter-company loans
Audience
Who is this for?
Foreign-owned subsidiaries
Foreign-owned subsidiaries with cross-border group transactions.
Associated enterprises
Companies with associated-enterprise dealings.
Group structures
Groups with management fees, royalties, or inter-company services.
The process
What it involves
Businesses must keep documentation covering the nature of the transaction, the relationship between parties, the pricing method, commercial rationale, agreements, invoices, financial data, and supporting evidence. Certification and reporting may also be required in many cases.
Eraqus support includes transaction mapping, record collection, agreement review coordination, TP study coordination, Form 3CEB coordination where applicable, and alignment with accounting and tax records.
01
Map related-party transactions
02
Collect records and evidence
03
Review agreements
04
Document the pricing method
05
Coordinate TP study and Form 3CEB
06
Align with accounting and tax records
Before you begin
Key considerations
01
Mapping all related-party and cross-border transactions.
02
Agreements and invoices.
03
Supporting financial data.
04
Pricing method and commercial rationale.
05
TP study and Form 3CEB coordination where applicable.
After incorporation
Ongoing compliance and the right choice
Transfer pricing should not be addressed only after the financial year ends. Business model, inter-company agreements, invoicing patterns, and accounting records should be aligned from the start.
Describe where your business stands and what you plan next. The team will help you understand the structure, documentation, and compliance that fit your situation.