International Tax /Transfer Pricing (TP)

Global tax structures with cross-border transactions.We offer TP advisory to compliance and tax office responses.

Service Overview

International tax and transfer pricing are core tax areas that affect the entire global business structure—overseas subsidiaries, holding companies, related-party transactions, royalties, service fees, and financial transactions. Tax authorities in each country examine related-party transactions with a focus on substance and the arm’s-length principle, and the importance of documentation and advance review continues to grow.

Our Principles

Operating Principles

We jointly review the client’s facts and circumstances, the purpose of the transaction, and the applicable tax laws and filing procedures to present a practical, executable tax response.

Key Services

Establishing transfer pricing policy and reviewing transaction structures
Supporting transfer pricing documentation such as Master File / Local File
Tax review of inter-company services, royalties, and financial transactions
Diagnosing international tax risk and establishing response measures
Tax review of overseas subsidiary and holding company structures

Key business decisions often bring tax considerations, we work with you to review and assess options tailored to your goals.