Pricing Policy
Introduction:
This Transfer Pricing Policy outlines the principles and methodologies 360 Securities applies in its intercompany transactions to ensure compliance with applicable transfer pricing laws and regulations. The policy aims to establish arm's length pricing for transactions between related entities within the 360 Securities group.
1. Scope:
This policy applies to all intercompany transactions involving the transfer of goods, services, intellectual property, or financial instruments between 360 Securities and its affiliated entities.
2. Objectives:
• To ensure compliance with transfer pricing regulations in all jurisdictions where 360 Securities operates.
• To minimize the risk of transfer pricing adjustments and penalties by tax authorities.
• To provide clear guidelines for setting and documenting transfer prices.
3. Transfer Pricing Principles:
• Arm's Length Principle: All intercompany transactions will be conducted at arm's length, meaning the terms and conditions will be consistent with those that would have been agreed upon by independent parties under similar circumstances.
• Transfer Pricing Methods: The following methods may be used to determine arm's length prices, depending on the nature of the transaction:
• Comparable Uncontrolled Price (CUP) Method
• Resale Price Method
• Cost Plus Method
• Transactional Net Margin Method (TNMM)
• Profit Split Method
• Selection of Transfer Pricing Method: The most appropriate method will be selected based on the comparability of transactions, availability of data, and the nature of the intercompany transaction.
4. Documentation:
Comprehensive documentation will be maintained for all intercompany transactions, including agreements, pricing policies, and supporting analyses.
Transfer pricing documentation will be prepared in accordance with local regulations and the OECD Transfer Pricing Guidelines.
5. Review and Adjustment:
Transfer prices will be reviewed annually or more frequently if there are significant changes in business circumstances or market conditions.
Adjustments to transfer prices may be made to ensure continued compliance with the arm's length principle.
6. Dispute Resolution:
In the event of a transfer pricing dispute with tax authorities, [Company Name] will seek to resolve the matter through appropriate administrative or judicial channels.
Advance Pricing Agreements (APAs) may be considered to provide certainty on transfer pricing arrangements for significant transactions.
7. Roles and Responsibilities:
The 360 Securities is responsible for overseeing the implementation and compliance of the Transfer Pricing Policy.
Each business unit involved in intercompany transactions is responsible for adhering to the policy and maintaining accurate records.
Conclusion:
360 Securities is committed to adhering to the arm's length principle and maintaining transparency in its transfer pricing practices. This policy will be reviewed and updated as necessary to reflect changes in transfer pricing regulations and business operations.