Introduction

Transfer pricing advisory has evolved from a compliance exercise to a strategic function. OECD guidelines increasingly stress proactive TP management and documentation, requiring expert interpretation and business alignment.

Scope of Advisory Services

• TP policy design and documentation

• Benchmarking and comparables analysis

• Value chain structuring and restructuring

• APA strategy and litigation support

OECD’s Expectations

• TP is not a formulaic exercise, it requires understanding of business models.

• Strategic TP advice supports effective BEPS compliance and dispute avoidance.

Benefits of Proactive TP Advisory

• Minimizes risk of double taxation

• Helps align with substance over form principle

• Supports global consistency in documentation

Conclusion

Strong TP advisory plays a crucial role in building defensible and future ready pricing policies. MNEs should treat transfer pricing as an integrated strategic issue, not just a tax requirement.