The intensity and focus by tax authorities worldwide toward transfer pricing and international tax is unprecedented. With the transparency of such high-profile risks in mind, multinational companies are motivated to deeply understand the value creation of their supply chain, as well as the inherent risks, respective intangible property footprint and potential layers of digital commerce, all of which can inadvertently unravel your transfer pricing strategy without proper diligence toward creating a globally-consistent, locally-tuned value chain story.
Every company experiences challenges within the various stages of its life cycle and often the growth strategy alone can drive how dramatic of a tax transformation may be necessary to bring the tax and business models together. Companies who are naturally engaging in ongoing M&A growth as well as those pursuing a divestiture strategy to re-focus on core competencies are the most common candidates for post-merger integration alignment. Most commonly, companies with latent integration of previous acquisitions have been challenged to reconcile their transfer pricing due to systems, processes, or technology issues.
The daily headlines are crowded with mixed messaging around store closures, M&A activity, and the impact of globalization. Multinationals must compete with increasingly nimble supply chains and address operational challenges never faced before, some that spawn from technological advances, such as "big data," while others are struggling under the weight of an aging infrastructure.
The first realization that a company is evaluating its competitive position in the market, assessing its global footprint, or surveying growth or acquisition opportunities is the ideal time to involve transfer pricing and international tax strategists in the conversation. The Aptis Global team brings over 100 years of collective, diverse expertise in seeing companies through the operational transformation journey with measurable, sustainable results. We take the time to understand the operational side of your business and can serve as the bridge for a tax department that may not have experienced a supply chain transformation or come alongside a seasoned team to serve as a sounding board, or as a sparring partner, throughout the process.
The OECD's core message in Base Erosion and Profit Shifting (BEPS) is loud and clear: the business and tax models must be in alignment. In many ways, the BEPS insights are back to the future in understanding the fundamental business model yet the bar is now much higher in ensuring that the critical capital, control, and contracts reflect the spirit of the true business relationship. As the spotlight is now focused on transfer pricing as well as international tax, it is critical that both areas of expertise are part of the dialogue in creating a defendable structure.
Aptis Global's integrated transfer pricing and international tax team is able to bring an independent, integrated solution, align with a company's internal team or become part of a broader team of advisors, whichever teaming approach brings the best practice solution in the most efficient game plan. Our independence brings you flexibility in creating a teaming solution that works best for your company's resources.