Recent developments have triggered a higher focus on tax and transfer pricing risk managemenl, and the need for specialized professionals in this area is increasing as new tax accounting rules are set forth. An example of this is the interpretation number 48 (FIN 48) Accounting for Uncertainty in Income Taxes, issued by the Financial  Accounting Standard Board (FASB). FIN 48 together with other recent developments has sharpened the focus on all farms of tax and transfer pricing risks of MNEs.

In order to respond to this increasing need to recognize tax and transfer pricing risks and to identify methods for quantifying and managing such risks, Transfer Pricing Associates has developed tools to assess tax and transfer pricing risk arising from future structuring/restructuring as well as from inter-company transactions already in place. These tools are listed as follows:

1. Country and risk matrix allows multinationals to assess whether their global/regional transfer pricing master file supports the local country transfer pricing requirements. For the risk assessment the determination is based on: a) complexity of specific documentation to be prepared; b) deadline for submitting documentation; c) language requirements; d) amount of penalties; e) audit history; f) financial performance of the local group company; and g) sophistication of the local tax administration.
2. Disclosure and maintenance manual: this tool illustrates the division of responsibilities for creating, managing, monitoring, and updating the layers of transfer pricing documentation. It also indicates who is authorized to disclose certain transfer pricing documents to the relevant stakeholders.
3. Recognition and measurement process: the process leads to an objective determination of your tax  provision relating to your global transfer pricing risks.
4. Customs duty risk assessment matrix, the customs valuation methodology mostly used is the WTO "Transaction Value" Method. This matrix allows multinationals to use due care to ensure that commercial documents and information appropriately reflect the information necessary to determine a reasonable and fair value under the local rules.
5. Business Process Analysis: this tool is used by Transfer Pricing Associates to assist companies also during the design phase with a qualitative assessment of the transfer pricing risk deriving from envisaged restructurings as well as from existing business configurations.