Designing a transfer pricing policy can be a complex process that involves several factors such as the nature of the transaction, the regulatory environment, the business strategy, and the tax implications. Transfer pricing refers to the practice of pricing transactions between related entities such as subsidiaries, affiliates, or parent companies.

Here are some key considerations to keep in mind when designing a transfer pricing policy:

Understand the regulatory environment

Transfer pricing rules vary by country, so it's essential to have a good understanding of the regulations in each jurisdiction where the company operates. Many countries follow the OECD Transfer Pricing Guidelines, which provide a framework for determining arm's length pricing.

Identify the nature of the transaction

The type of transaction will impact the transfer pricing policy. For example, a transfer of tangible goods may have different pricing considerations than the transfer of intangible assets such as intellectual property or services.

Determine the most appropriate transfer pricing method

There are several transfer pricing methods, including the comparable uncontrolled price method, resale price method, and cost-plus method, among others. Each method has its strengths and weaknesses, and the choice of method will depend on the nature of the transaction and the regulatory environment.

Develop internal policies and procedures:

The company should have clear internal policies and procedures for transfer pricing, including documentation requirements and internal review processes. These policies should be consistent with the company's overall business strategy and goals.

Review and update the policy regularly

Transfer pricing policies should be reviewed and updated regularly to reflect changes in the business environment, regulatory requirements, and economic conditions.

Get expert advice

Transfer pricing can be a complex area, and it's important to get expert advice from professionals such as tax advisors, accountants, and lawyers to ensure compliance and minimize risks.

Overall, designing a transfer pricing policy requires careful consideration of various factors and should be done with the help of experts to ensure compliance and minimize risks.

TPNOMIX assists consultants/ advisors and multinational companies in framing policy for new or existing inter-company transactions supported by robust benchmarking analysis.

How it Works
  • We will understand the overall business operations and the proposed (or existing) inter-company transactions;
  • For this purpose, we will schedule meetings/ functional interviews with your relevant team members;
  • Basis the understanding obtained, we will document the function, assets and risk (‘FAR’) profile of the transacting parties and seek your confirmation on the same;
  • Based on the confirmed FAR profile, we will suggest an appropriate pricing policy for the transaction
  • We will undertake benchmarking analysis to support the designed pricing policy and discuss its results with you before finalising the pricing policy report.