A diagnostic review comes before any documentation work begins. It establishes which entities are in scope, which thresholds are crossed and what documentation is actually required — so the work that follows is scoped to the obligation rather than to an assumption.
We examine your intercompany arrangements to establish where exposure sits, how likely each position is to be challenged, and what a challenge would cost in additional tax, interest and penalties.
The review covers:
- Mapping of the group structure and identification of every category of controlled transaction
- Analysis of how transfer prices are currently set, and whether the method is applied consistently across entities and across periods
- Accurate delineation of each transaction — whether the contractual allocation of risk is supported by the conduct of the parties and by their capacity to control and assume that risk
- Identification of transactions with no supporting analysis, including balances that have arisen informally, such as unremunerated intercompany current accounts
- Review of open prior years for exposure carried forward
A diagnostic review frequently reduces the scope of the work that follows, by establishing the extent of the obligation before any documentation is prepared.
Get in touch
Send us a message
Tell us about your intercompany transactions and we’ll be in touch.