ECS assists clients with several aspects of “local file” implementation including:
- Reviewing intercompany transactions to determine the appropriate units of account and material income tax positions, and to create appropriate recognition and measurement methods.
- Providing advice on audit policies and administrative procedures followed by the tax authorities.
- Preparing transfer pricing documentation to inform management.
- Setting up measurement procedures that involve calculating the amount of tax benefits related to transfer pricing, projecting alternative outcomes that might be realized in resolving the position, calculating probabilities of realization of each outcome, and cumulative probability analyses.
- Creating an implementation process to update transfer pricing analysis on annual basis.