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••• Transfer Pricing
The definition of a transfer pricing transaction is when two or more companies, who are incorporated in to different countries but belong to the same Group of Companies or where one company is a subsidiary of another company are involved in either the buying and /or selling of services or products between each other, prior to or after selling or acquiring these services or products from a third party.
In terms of the OECD and the certain countries that have promulgated transfer pricing legislation the margin or profit between these two or more companies should be arrived at in a manner that is fair and equitable as if these to or more companies where trading in a normal arm’s length business arrangement.
In order to arrive at and maintain a acceptable transfer pricing margin Cheetah Management Services offers a full and comprehensive planning review and implementation of a transfer pricing structure. The CMS Transfer Pricing Model includes, inter alia, the following key aspects:
• Creation of the documentation required for an acceptable transfer pricing methodology.
• Determination of an adequate transfer pricing margin.
• Arm’s length agreements and contracts required to support the transfer pricing methodology.
• An audit program for regular reviews of the transfer pricing formula and margin to ensure its compliance with the relevant legislation in the various countries.
The application of the applicable transfer pricing model correctly designed and formulated ensures the a multi-national Group of Companies can take advantage of low tax jurisdictions and improve the overall group consolidated income after taxation.
••• Holding Companies
••• Patent Licenses & Application
••• Intellectual Property
••• Use of Double Taxation Agreements
This document can be downloaded in PDF file format
••• VAT Structures
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