QCG Transfer Pricing seeks to transform your intercompany analysis into a value driver for your organization. We provide comprehensive documentation solutions that transform your transfer pricing analysis into a powerful value driver for your global organization. Our innovative approach, combined with specialized tools, designed specifically by transfer pricing specialists, and commitment to technical excellence, enhances efficiency while optimizing results and significantly mitigates transfer pricing compliance risk with robust and precise documentation.
Maintaining robust transfer pricing documentation is essential to demonstrating that your intercompany transactions comply with the arm’s length principle. Our in-house-developed AI-powered tool, Transfer Pricing Diligent®, conducts an in-depth analysis of all relevant factors, yielding high-quality and robust compliance documentation that optimizes tax outcomes while providing you the certainty that transfer pricing risk is minimal in all for all jurisdictions where you operate.
Tax authorities often require the submission of detailed reports on related-party transactions. We provide expert assistance to ensure timely and accurate filings, reducing the risk of costly penalties.
Intercompany transactions should be supported by strong economic reasoning. We create comprehensive defense files that support your transfer pricing policies, mitigate audit risks, and strengthen your tax position.
BEPS Action 13 establishes the requirement that multinational enterprises must prepare a Master File outlining their global structure, value chains, and transfer pricing policies, alongside a Local File demonstrating arm’s length compliance at the local level. We assist in preparing these documents in accordance with OECD Guidelines, ensuring full regulatory compliance.
Multinational groups with annual consolidated revenues exceeding €750 million must submit a Country-by-Country Report (CbCR) detailing global income, costs, and tax burden. We help businesses comply with this important tax reporting requirement.
Certain jurisdictions offer safe harbor regimes to simplify transfer pricing compliance, such as Mexico’s maquiladora regime or the OECD’s framework for low-value-adding services. We assess your eligibility and provide guidance to ensure compliance while optimizing tax efficiency.
The OECD’s Pillar 2 framework introduces a 15% global minimum tax to ensure large multinational groups pay a minimum effective tax rate, regardless of where they operate. This applies to groups with consolidated annual revenues of €750 million or more and requires additional tax payments in jurisdictions where the effective rate falls below the global minimum.
Our can assist:
With our support, you can navigate this complex regulatory change while minimizing risks and avoiding penalties.
To increase tax certainty and reduce compliance costs for routine distribution and marketing activities, the OECD has introduced Amount B under its Pillar 1 framework. This standardized approach has been adopted by certain jurisdictions. We evaluate its applicability to your business and assist in implementation.
APAs provide tax certainty by securing prior approval of your transfer pricing policies from tax authorities. However, obtaining an APA requires a strategic approach and a well-documented case. We assist in the negotiation and execution of unilateral, bilateral, and multilateral APAs, simplifying the process and ensuring regulatory compliance while minimizing disputes.
For further review, check out the APA Guide drafted by our Managing Partner for the Inter-American Center of Tax Administrations (CIAT): CIAT APA Guide