Does your business face potential risks due to transfer pricing?

Transfer pricing (TP) involves determining the prices for transactions involving the exchange of goods, services, intangibles, and financing between related individuals or entities within a Group.

All transactions involving related parties must be conducted at arm's length prices, meaning that the prices should be comparable to those set between independent parties in similar transactions. The main challenge is twofold: firstly, establishing the appropriate arm's length transfer prices, and secondly, safeguarding them against potential challenges from tax authorities. Additionally, managing transfer pricing risks related to tax planning and compliance poses an internal challenge within a group.

The complexity of transfer pricing poses risks of costly errors. To navigate through the constantly changing tax regulations, seeking specialized tax guidance is essential. With the tax authorities providing a foundation for implementing transfer pricing, taxpayers are obligated to fulfill their responsibilities and comply with the transfer pricing regime.

Our transfer pricing department provides a comprehensive array of transfer pricing services. Our team of skilled tax and transfer pricing experts will guarantee that you receive top-notch assistance in handling your transfer pricing matters. Furthermore, our extensive network of member firms in 130 countries worldwide and strategic capabilities enable us to offer a well-rounded approach to meet your organization's transfer pricing requirements.

 
Transfer Pricing Documentation
The issue of transfer pricing continues to be of utmost importance for businesses on a global scale. It specifically relates to controlled transactions involving related parties, extending beyond those within the same group to encompass parties with direct or indirect control, including control over the board of directors.

In compliance with the Yemeni Income Tax Law, Transfer pricing focuses on establishing prices for transactions between related companies that are consistent with the arm's length principle. This principle dictates that prices in related party transactions should be equivalent to prices in third party transactions under similar conditions.

Transfer Pricing Advisory
  • High-level transfer pricing review
  • Transfer pricing due diligence
  • Transfer pricing planning
  • Transfer pricing strategy setting 
  • Value chain alignment

Managing Transfer Pricing Conflict
  • Advance Pricing Agreement
  • Mutual Agreement Procedures
Transfer Pricing Dispute Resolution
  • Transfer pricing audit defense
  • Litigation and appeal