Transfer pricing

In today’s dynamic business environment, it is essential that MNEs have real-time access to in-depth foreign country tax intelligence in order to seize potential opportunities and manage global risks. Moreover, keeping abreast of legislative and regulatory tax changes as well as understanding what tax trends are on the horizon, not only provides the necessary information for properly administering the tax function, but also can lead to a competitive advantage in the marketplace.

China Desk gathers a team of specialists who can assist you gaining in-depth understanding of both the Danish and the Chinese tax systems, developing strategies and mitigating risks. Our services include:

Documentation and Planning
PwC’s global transfer pricing network can help you develop transfer pricing documentation and defence files that are coordinated across all your territories, and consistent with your needs. Using our Global Core Documentation™ system, we prepare a global core document package containing common data and background information. This core documentation is then appropriated by each country as part of its separate country report, with the support of our team. The process is coordinated globally to ensure consistency and accuracy in disclosure.

Tax Audit Defence and Dispute Resolution
Our tax controversy and dispute resolution professionals will help you gain a better understanding of your company’s tax risks and exposures. If tax controversies or disputes arise, we will be there to assist you with implementing consistent and defensible practices and policies. Our international team coordinates and aligns strategy across jurisdictions in order to prevent disputes from developing into larger business concerns.

Advanced Pricing Agreements
An APA is a contract, usually for multiple years, between a taxpayer and at least one tax authority specifying the pricing method that the taxpayer will apply to its related-company transactions. These programs are designed to help taxpayers voluntarily resolve actual or potential transfer pricing disputes in a proactive, cooperative manner, as an alternative to the traditional examination process.

An APA offers a company several other benefits. It provides greater certainty on the transfer pricing method adopted, mitigating the possibility of disputes and facilitating the financial reporting of potential tax liabilities. Importantly, an APA also reduces the incidence of double taxation, and the costs associated with both audit defense and documentation preparation.

PwC has substantial experience helping companies obtain APAs with the Danish and/or the Chinese Tax Authorities. We can work with you to develop strategies at both the global and local level, and guide you through the process of requesting APAs to help you ensure successful outcomes.

Value Chain Transformation
China’s growing domestic market demand challenges the traditional view on the Chinese market and the way MNEs operate in China. Businesses are transforming their value chain in China and with China, from the traditional low-cost manufacturing model towards a focus on R&D, managerial and financial presence.

How to manage these challenges and transform your business in a tax-advantaged manner?

VCT mobilizes impressive resources across geographic and service lines to create a "one-stop-shop" for professional advice and knowledge.

Using our Value Chain Transformation, we can help you:

  • Develop a more competitive customer service proposition
  • Achieve a rationalized manufacturing capacity and optimized physical distribution network
  • Create a sustainable, structural tax improvement, increasing shareholder value and cash flow
  • Create optimal processes for operational leadership
  • Align your tax/fiscal and operational models
  • Establish potential synergies within your supply chain and operating structure
  • Obtain total visibility across the supply chain through single ownership of inventory
  • Facilitate the management of euro pricing and greater pricing transparency
  • Centralize transaction processing
  • Align profits with restructured business processes
  • Achieve the flexibility to accommodate future business changes