Foreign Subsidiaries

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Foreign Subsidiaries

Do you have all the necessary transfer pricing policies and risk assessments in place for the intercompany related party transactions of your foreign subsidiaries?

Ask us how we can assist you with:

Transfer pricing planning and implementation of new business structures
Preparation of transfer pricing documentation, Master File and Local File
BEPS and Country by Country Reporting implementation
Development and review of transfer pricing policy
Transfer pricing risk reviews, APAs and audit defense
Benchmarking studies covering all types of transactions and regions with access to databases
Preparation and review of intercompany agreements
Fast-track intercompany agreement drafting
In-house transfer pricing workshops and training sessions
In-house transfer pricing advisory

27 Mar

When the Berry Ratio Works – And When It Becomes a Red Flag

The Berry Ratio may sound light‑hearted, but in transfer pricing it is one of the most debated Profit Level Indicators (PLIs) used under the Transactional Net Margin Method (TNMM). Simple in formula yet demanding in application, the Berry Ratio continues to attract scrutiny from tax authorities worldwide.

Transfer Pricing in an Era of Geopolitical Turmoil

Geopolitical volatility has moved from the margins of risk management to the centre of transfer pricing strategy. For multinational groups operating across Australia, Asia and Europe, geopolitical turmoil is no longer a short-term disruption to be explained away in annual documentation.

Singapore Budget 2026 - Strategic Implications for Multinational Groups

Singapore’s Budget 2026 sets out a clear strategy to strengthen competitiveness in a changing global environment. The Budget introduces important tax measures while confirming Singapore’s implementation of OECD Pillar Two global minimum tax rules.