TPGS believes that transfer pricing assistance should not be provided on a once-off basis. Instead, risks related to transfer pricing must be managed continuously, developing in the context of the specific business needs of the company. Transfer pricing policies must be robust in order to withstand challenges from tax authorities; the risk of such a potential challenge must be considered when evaluating the suitability of adopting the TP policy.
It is imperative that TP policy is not developed unilaterally by a finance team without the involvement of other departments in an organisation. Key stakeholders should participate in the identification of any relevant issues and the development of the functional, asset and risk profile of the organisation. It is also important that the legal, tax and accounting teams develop a close working relationship in order to most effectively implement TP policy.