Cosmos International Management Co., Ltd.



Service (Transfer Pricing & International Tax Consulting)


Transfer Pricing Consulting:
Transfer Pricing Advisory

Multinational companies conduct transfer pricing-related daily activities including preparing / amending internal documents such as various inter-company agreements and transfer pricing policy memorandum, setting a pricing policy for a new transaction, and determination of pricing based on the policy. The internal documents related to these daily activities will definitely be reviewed by tax authorities when tax examination is conducted. If the tax authority considers that there is a high probability of income transfer to overseas because the documents are not prepared or they are not sufficient, such consideration may highly likely lead to tax adjustment. Thus it is essential for the daily transfer pricing activities to get support and review by transfer pricing specialists in order to follow transfer pricing regulations and arm’s length principle.

Additionally, considering that transfer pricing enforcement has been so strong globally, receiving second opinion from multiple specialists is an effective tool to carry out more definite risk protection measures.

We provide the transfer pricing advisory for the above-mentioned purposes with fixed fees.


Service Contents

  • Meeting (once a month)
  • Advice (response on queries via telephone and e-mail)
  • Interpretation of simple English and Chinese financial / taxation documents (financial statement etc.)
  • Providing latest transfer pricing / taxation information on relevant countries

Service Fees

Minimum JPY 50,000 per month, depending on the size of overseas business (excluding sales tax and expenses)


Please contact us for the detail of this service.

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