Transfer Pricing

Transfer Pricing pertains to the arm’s length pricing of inter-company transactions for multinational groups faced with the complexities of evolving tax regulations and policies, worldwide. Our transfer pricing practice assists clients in managing risks by adopting a holistic approach, combined with pragmatic transfer pricing solutions that are aligned to business operations and objectives.

Segal GCSE LLP’s transfer pricing offering for clients covers key elements of the transfer pricing life-cycle, including:

Planning

Develop inter-company pricing policies
Integrate and align inter-company policies following mergers/acquisitions

Operational Transfer Pricing

Review inter-company results in context of policies including year-end positions
Assist with drafting inter-company agreements
Integrate inter-company accounting and financial systems
Inter-company invoicing
Update pricing policies and review year-end positions, update inter-company agreements, integrate inter-company accounting systems and invoicing following merger/acquisition.

Controversy management

Risk review of inter-company pricing policies to proactively mitigate risks
Manage local country transfer pricing reviews and audits including strategizing responses to tax authorities
Support multi-jurisdictional transfer pricing audit resolution by way of Mutual Agreement Procedure (MAP) by engaging with Competent Authorities (CA), where required
Proactive engagement with tax authorities to minimize transfer pricing controversy by using the Advance Pricing Agreements (APA) mechanism, where appropriate
Conduct due diligence reviews of intercompany transactions and policies, prior to an acquisition.

Compliance

Preparation of transfer pricing documentation in accordance with local country requirements (e.g., Canada Sec 247 and US IRC Sec 482 Regs), and the OECD BEPS Action 13 Global and Local file framework
Country-by-Country Reporting (CbCR) for headquarter companies and their global subsidiaries
File local country transfer pricing disclosure forms and notifications

Meet Our Transfer Pricing Leader

Avinash S. Tukrel is a Principal and leads our Transfer Pricing Practice, based in Toronto, Canada.

As the practice leader, Avinash works with his clients in navigating complex tax and transfer pricing problems with a pragmatic approach collaborating with international member firms in the Moore Global Network.

He has over 15 years of international transfer pricing experience gathered in Canada, the United Kingdom (UK), Malaysia, Australia and India.

Avinash has led numerous transfer pricing planning, compliance, operational and controversy management engagements for his clients in the pharmaceutical and life sciences, technology, consumer and industrial products as well as diversified services sectors.

Telephone: (416)-774-2446

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