Transfer Pricing

Transfer pricing rules govern the prices that related companies charge each other for goods, services, intellectual property, and intra-group loans. In Southeast Asia, transfer pricing is one of the most heavily scrutinized areas of corporate tax — every jurisdiction now requires contemporaneous documentation, and several enforce BEPS Action 13 master-file/local-file standards.

What we deliver

• Transfer pricing documentation — Local file, master file, and CbCR preparation aligned with OECD BEPS Action 13 + local regulations (Vietnam Decree 132/2020, Indonesia PER-29/PJ/2017, Thailand DG Notification 407/2562, Singapore IRAS TP guide).
• Functional and comparability analysis — Identifying arm’s-length ranges for intra-group transactions using regional comparables databases.
• Policy design and restructuring — Setting defensible transfer pricing structures during initial entity setup, expansion, or supply-chain reorganization.
• Audit defence — Representing clients during transfer pricing audits with local tax authorities; negotiating settlements and APAs.
• Pillar 2 (GloBE) impact modelling — For groups with EUR 750M+ revenue, projecting top-up tax exposure across Thailand, Singapore, Vietnam, and Indonesia.

Who it is for

Multinational groups operating in two or more ASEAN markets, foreign-invested companies receiving intra-group services or financing, and regional holding-company structures preparing for IRAS / GDT / DGT / Revenue Department transfer pricing audits.

How we engage

Project-based engagements for documentation cycles, retainer for ongoing TP support, or as-needed for audit defence and APA negotiations. Same team across countries for consistent treatment of group-wide policies.