Enhance Compliance with iVC Consulting’s Custom Transfer Pricing Solution

Does your Transfer pricing model illustrate decision-making power in line with your business operations?

At iVC Consulting, we pride ourselves on offering innovative solutions that ensure our clients stay ahead of regulatory challenges. Recently, our team members - Stelios and Aliaksandra - developed a bespoke Excel-based tool for one of our clients, specifically designed to monitor the allocation of decision-making power across leadership and different jurisdictions within their MNE group.

Tailored Solution for Effective Risk Management

The original tool takes a list of key decision-makers at the highest levels of management and assigns a quantitative score to the various functions they perform. Parameters include risk management and assessment responsibilities, strategic management involvement, leadership team participation, committee roles, and more. By analyzing these factors, our client can clearly see the geographical distribution of its key decision-makers and proactively assess the risk of being challenged by tax authorities.

This comprehensive approach allows our client to effectively monitor the shift of decision-making power across multiple jurisdictions and take timely and appropriate actions to maintain the centralized business model. By using the tool, our client has data-driven evidence to support its claim of where leadership is located, thereby improving compliance with international and local CIT regulations.

A Powerful Solution for Your Business

By enabling you to monitor the distribution of decision-making power, our tool can help you to identify the appropriate moment when your transfer pricing model needs to be changed, for instance by shifting to a profit split. Basing the weighting of entities' contribution across jurisdictions on commercial facts rather than tax-driven motives enhances credibility from an economic substance perspective. This is vital for clients who need to satisfy economic substance tests, as well as those who need to carry out benefit tests for management services to support that their management is genuinely based in a particular country.

Why Choose Our Tool?

• Proactive Risk Management:: Identify and mitigate areas of risk that may be challenged by tax authorities.

• Effective Compliance: Ensure your business model aligns with international and local CIT rules.

• Credible Profit Split: Base your profit split on robust data-driven commercial factors, meeting OECD guidelines.

• Economic Substance Verification: Demonstrate genuine management presence in a specific jurisdiction(s).

At iVC Consulting, we help you stay compliant, credible, and competitive in today’s complex regulatory environment. Get in touch to learn how our tailored solutions can support your business in maintaining a resilient and fitting transfer pricing model ready to withstand any challenge.

Contact us today to discuss how we can tailor our solutions to meet your specific needs and ensure your business remains super-compliant!