Risk Assessment, Documentation and Benchmarking

Risk Assessment

Identifying and quantifying transfer pricing risk is an important first step toward implementing a tax efficient transfer pricing policy and mitigating audit risk. This is a cost-effective solution for any enterprise seeking to understand the extent of its transfer pricing risk.

Our tax professionals will identify transfer pricing risks and potential planning opportunities through an analysis that includes:

• An industry wide comparability analysis.
• Review key related party transactions and current transfer pricing policy.
• Identify transactions with material transfer pricing risk based on current financial performance.
• Advise on cost-effective solutions to mitigate transfer pricing risk.
• Flexible scope and depth of assessment depending on client needs.

Transfer Pricing Documentation

Transfer pricing documentation is the solution for taxpayers seeking to fully document and support a transfer pricing position, satisfy compliance requirements, and avoid transfer pricing penalties. Our transfer pricing experts and tax professionals will provide a complete transfer pricing documentation package that includes:

• A comprehensive industry wide comparability analysis;
• Review and analysis of all related party transactions;
• Function and risk analysis;
• Economic analysis and comparable search using leading commercial database;
• Determination of an arm’s length range.

Our multilingual team can provide services and produce reports in English, Japanese, or Chinese at the request of the client.

Benchmarking Analysis

A benchmarking analysis measures prices or profit level indicators for specific transactions or entities to determine an appropriate arm’s length range. Benchmarking is an ideal solution for Japanese subsidiaries that do not require full transfer pricing documentation, but require guidance on the transfer prices appropriate under Japan’s regulations.

A benchmarking analysis conducted by the transfer pricing experts and tax professionals at Grant Thornton Japan will include:

• Determine arm’s length range of price or profit levels through a comparability search on a leading commercial database.
• Search screens are based on your existing transfer pricing policy and business and industry analysis.