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Transfer pricing consulting services

More protection at less cost for transfer pricing with AGS Consulting

In recent years, more and more foreign-owned companies including small and mid-sized firms are being examined for transfer pricing in Japan for potential assessment, and the need to prepare proper documentations in place is becoming ever more urgent.

Many companies, including start-ups whose early years may be mitigated from scrutiny, only start thinking about transfer pricing after crippling assessments a few years later which can amount to some tens of millions of yen.

Earlier preparations of benchmarking studies for example, are therefore recommended to show that your company is making serious considerations to deal with transfer pricing issues, which can lower or avoid the risk of assessment.

At AGS Consulting, we provide an affordable and efficient way to benchmark, document and update your transfer pricing needs without compromising the high standard and quality of detail required to defend your business operations in Japan from unwarranted assessments from the tax authorities.

There are various ways to defend your company from transfer pricing taxation depending on your business phase, level of protection required, as well as budget. At AGS, we offer the following services to cater for your transfer pricing needs at reasonable costs and quality at par with the high standards required of your company.

Services Detail Deliverable Cost (app.)
Benchmarking(BM) Inventory Service Royalty Computation of arm’s lengths range BM report From JPY0.6mil.
Transfer pricing policy Formulation of internal pricing policy Policy report From JPY1.8mil.(+number of BM)
Local File (LF) Preparation of LF based on Japanese regulations Local File From JPY1.5mil.(incl. One BM)
Updates etc. Updates of existing LF reports Updated LF From JPY0.8mil.
Preparation and review of contracts Preparation/review of inter-company agreements Contracts or review memo from a transfer pricing perspective From JPY0.4mil
IP Valuation DCF valuation of intangible assets Valuation report From JPY1.8mil
APA / MAP Filings for negotiations with the National Tax Agency of Japan APA / MAP application reports From JPY3.0mil.(for filing only)
Filings of MF/Notification of Ultimate Parent Entity in Japan Filings of BEPS related documents in Japan Remittance notification from e-Tax JPY200,000
Audit defense Accompany taxpayer at tax examinations Position paper etc. From JPY30,000 / hour