Resale and Wholesale distribution sectors involving consumer goods, electronics, apparel, pharmaceuticals and industrial components are being forced into change as global supply chain shifts take effect, digital sales growth ramps up, and international tax standards evolve. While opportunities exist within this arena for growth as well as increased scrutiny.
Routine distributor margins vary based on industry. Tax authorities are increasingly challenging benchmark studies when brands, digital platforms, or services are combined with products. To avoid penalties and double taxation, transfer pricing policies must now match customs valuation for imported goods with intercompany pricing.
Key compliance priorities:
- Transfer pricing documentation, including detailed analysis of functions performed, assets employed, risks assumed and value chain description;
- Maintain consistency across tax, customs and finance by ensuring synchronized pricing and compliance reporting processes;
- Strategies for dispute prevention and resolution in high risk jurisdictions.
How T1 Advisory Supports Clients
- Designing transfer pricing policies that accurately reflect their real functions and risks as distribution entities.
- Preparing robust documentation (Master File, Local Files and Country-by-Country Reporting) that aligns with OECD standards while reflecting commercial realities.
- Benchmarking intercompany margins with local comparables adjusted for market roles, size and industry dynamics.
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