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Transfer pricing compliance and documentation
Revenue authorities are focusing more widely and intensely on transfer pricing issues. From documentation to helping your practices match your policies, our teams of experienced professionals can help interpret the intent of tax authorities wherever you operate or intend to operate.
The team
Takeshi Yatsu
EY Japan Technology Sector Tax Leader, International Tax and Transaction Services Leader, Transfer Pricing Advisory Leader; Partner Ernst & Young Tax Co.
Sanae Yamada
EY Japan Consumer Products & Retail Tax Leader; Partner, Ernst & Young Tax Co.
Takashi Ajita
EY Japan Health Sciences and Wellness Tax Leader; Partner, International Tax and Transaction Services (ITTS)/Transfer Pricing Advisory, Ernst & Young Tax Co.
What EY can do for you
Appropriately pricing and documenting your intercompany transactions to comply with various countries‘ rules and legislation is imperative in managing tax risk.
Documenting intercompany transactions is the first line of defense when your transfer pricing practices are challenged.
Whether you choose to apply a globally centralized approach or a decentralized approach to your documentation needs, you need to understand the rigorous transfer pricing scrutiny in the countries where you operate so that you meet the local requirements, particularly where there is heightened risk. This risk-based approach allows you to align your company‘s business and tax strategies with your risk profile.
Transfer pricing documentation
EY has developed TP Web™, a comprehensive transfer pricing documentation tool that can help you streamline your internal processes and generate reporting packages to support transfer pricing documentation requirements under BEPS Action 13.
Country-by-country (CbC) reporting
EY has also developed a separate CbC reporting tool “CbCR Web™” that helps you generate CbC reporting data, as required under BEPS Action 13.
Transfer pricing implementation - intercompany effectiveness
Operationalizing transfer pricing policies is a big challenge for many multinationals. EY has developed a structured and scalable framework for improving transfer pricing implementation and building integrated systems and processes across tax, business units and operations.
Our flexible approach can help you develop sustainable practices to execute, monitor and report intercompany transactions.
Managing your financial transactions transfer pricing
To help you simplify and automate relevant treasury and tax workflows, EY teams have developed the EY Intra-group Finance Web, an interactive platform for managing, pricing and documenting intra-group financing arrangements. Finance Web optimizes the following workflows:
- replacing manual tasks related to entering and documenting terms and conditions of transactions;
- determining credit rating estimates for group companies;
- retrieving comparable market data (through real-time connection) from third party financial databases / platforms;
- performing necessary adjustments; and
- generating loan agreements and TP documentation reports.
Global support
Located across the globe, our teams of experienced transfer pricing professionals have in-depth and broad knowledge of local and regional issues that can help interpret the intent of tax authorities in the countries where you currently operate or are planning to operate. As part of an integrated and extensive global network, our teams work seamlessly together from offices around the world, responding quickly to your global and local needs.
The team
Our latest thinking
The Tax Leader Imperative: How do you adapt to the changing tax risk landscape?
The 2021 EY Tax Risk and Controversy Survey finds businesses are bracing for more tax disputes. Learn how to assess and help manage tax risk and disputes.
Our globally connected tax network can help your tax function address complex issues, making sure you can operate confidently in today’s disruptive landscape.
