PRAS inc.

In order to reduce the transfer pricing risk of the group and satisfy the commercial requirements of multinational clients, we aid in the development of global transfer pricing policies and systems. In accordance with OECD regulations and local tax requirements, we also generate master files, local files, CbCR, and local forms pertaining to the pricing of all categories of international related party transactions. With the intention of assisting clients in comprehending their significant transfer pricing risks and how they impact the computation of tax contingencies for the purpose of accounting disclosure, we conduct thorough audits of transfer pricing systems by leveraging our extensive understanding and practical experience of tax authorities. In order to reduce the risk and magnitude of transfer pricing adjustments, interest, and penalties imposed by the relevant tax authority, as well as to minimize disruption to the company's day-to-day operations, we conduct transfer pricing reviews and audits in a proactive and strategic manner. With the aim of assisting multinational clients in the efficient management of transfer pricing risks and potential reduction of their overall tax rate, we develop value chain strategies and global and regional transfer pricing policies.