Transfer Pricing in the Spotlight: Building Transparency and Resilience in Intercompany Dealings

In today’s interconnected business environment, multinational groups are under increasing scrutiny from tax authorities and regulators. One area that continues to draw global attention is transfer pricing—the pricing of goods, services, and intellectual property exchanged between related entities within a corporate group. With the OECD’s Base Erosion and Profit Shifting (BEPS) initiatives reshaping tax landscapes, ensuring transparency, consistency, and compliance in intercompany dealings is no longer optional—it’s mission critical.

At Dawgen Global, we help organizations design, implement, and defend transfer pricing strategies that align with both business realities and regulatory expectations. Our approach combines deep technical insight, region-specific expertise, and a commitment to building resilient policies that stand up to audits, litigation, and change.

Why Transfer Pricing Is Under the Global Microscope

Transfer pricing was once a niche concern. Today, it’s a headline issue in boardrooms, finance departments, and tax audits worldwide.

• BEPS Action Plans by the OECD call for enhanced documentation, economic substance, and alignment of profits with value creation.

• Tax authorities are collaborating, exchanging information and demanding greater disclosure (e.g., country-by-country reporting).

• Multinationals are being challenged to justify how profits are distributed across jurisdictions and whether pricing reflects market realities.

Failing to proactively manage transfer pricing risks can lead to costly penalties, double taxation, and reputational harm.

Dawgen Global’s Approach: Policy with Purpose, Strategy with Substance

We work with businesses to ensure that transfer pricing arrangements reflect commercial substance, are economically justified, and meet the documentation standards required under BEPS and local tax laws.

1. Functional and Economic Analysis

We begin by deeply understanding your operations:

• What functions are performed?

• Where are risks assumed?

• How are assets—tangible and intangible—utilized across entities?

This analysis forms the backbone of a defensible transfer pricing policy that accurately captures value drivers and roles across your group.

2. Benchmarking with Regional Relevance

Our benchmarking studies are grounded in robust data sets and tailored to local realities. Whether you’re in manufacturing, distribution, services, or IP-heavy industries, we apply arm’s length principles using:

• Comparables from relevant markets

• Adjustments for regional cost structures

• Profit-based and transactional methods where appropriate

3. Robust Documentation and Risk Management

We provide full Master File and Local File documentation, tailored for BEPS compliance and aligned with tax authority expectations in the Caribbean and globally. This includes:

• Detailed narratives of your intercompany dealings

• Financial analyses supporting pricing structures

• Country-by-country reporting coordination (if applicable)

4. Proactive Audit Readiness and Defense

In the event of a transfer pricing audit or inquiry, we provide support with:

• Audit preparation and response strategies

• Negotiation and dispute resolution

• Advance pricing agreements (APAs) and MAPs where beneficial

Our goal is to build not just policies, but resilience—ensuring your arrangements hold up under scrutiny.

Transfer Pricing in the Caribbean: Local Expertise with Global Insight

While the BEPS framework is global, its implementation is local. Tax authorities in Jamaica, Trinidad & Tobago, Barbados, and other Caribbean jurisdictions are rapidly strengthening transfer pricing regulations, often in coordination with OECD guidelines.

Dawgen Global provides a unique advantage—a combination of:

• Regional expertise rooted in local laws and business practices

• Global alignment with international best practices and treaty frameworks

• Industry insight across sectors including finance, real estate, energy, and consumer goods

Whether your business operates in one country or across multiple jurisdictions, we ensure transfer pricing strategies are consistent, compliant, and commercially justifiable.

A Strategic Imperative, Not a Back-Office Task

Transfer pricing is no longer just a tax matter—it’s a strategic tool that impacts capital allocation, profit repatriation, supply chain design, and overall business resilience. At Dawgen Global, we position your intercompany pricing policies as part of a broader strategy to:

• Support business growth

• Enhance cross-border efficiency

• Avoid tax controversy

• Build stakeholder trust

Let’s Make Transfer Pricing Work for You

In a world of heightened transparency and regulatory convergence, your transfer pricing approach must be clear, consistent, and controlled. Dawgen Global is here to guide you—building frameworks that meet today’s standards and adapt to tomorrow’s challenges.

Next Step!