1. Purpose
This policy sets out Murzo Group’s high-level approach to transfer pricing and intercompany transactions.
The purpose of this policy is to:
- Establish a clear governance position on transactions between related entities
- Promote compliance with applicable tax laws and international standards
- Reduce the risk of tax disputes, penalties, and reputational harm
- Provide transparency regarding Murzo Group’s principles without disclosing sensitive commercial information
This policy forms part of Murzo Group’s broader tax governance and risk management framework.
2. Scope
This policy applies to:
- Transactions between Murzo Group and any related entities, affiliates, or connected parties
- Intercompany provision of services, goods, intellectual property, or cost sharing
- Cross-border and domestic related-party arrangements
- Existing and future group structures
This policy applies globally, irrespective of jurisdiction.
3. Governance Principles
Murzo Group’s approach to intercompany transactions is guided by the following principles:
- 3.1 Arm’s Length Principle: Intercompany transactions are intended to be conducted on an arm’s length basis, consistent with recognised international tax standards.
- 3.2 Commercial Substance: Transactions are entered into for genuine commercial reasons and reflect actual activities, functions, and risks.
- 3.3 Transparency & Documentation: Appropriate documentation may be maintained to support the nature and pricing of intercompany arrangements, where required by law.
- 3.4 Proportionality: Transfer pricing controls are applied proportionately, taking into account the size, complexity, and risk profile of Murzo Group’s activities.
4. Responsibility Allocation
Murzo Group maintains oversight of intercompany transactions through:
- Central governance and management review
- Use of internal controls and approval processes
- Engagement of professional advisers where appropriate
Each entity within any wider group structure remains responsible for its own local tax compliance obligations.
5. Intellectual Property & Services
Where intellectual property, services, or know-how are shared between related entities:
- Ownership and usage rights are defined contractually
- Compensation is intended to reflect the nature and value of the activity
- No implied transfer of ownership occurs
This policy does not disclose Murzo Group’s proprietary valuation methods or pricing models.
6. International & Cross-Border Considerations
Murzo Group recognises that:
- Transfer pricing rules vary by jurisdiction
- Local documentation or reporting obligations may apply
- Tax authority interpretations may differ
Murzo Group does not guarantee uniform tax treatment across jurisdictions and does not represent that all positions will be accepted by tax authorities.
7. Compliance & Risk Management
Murzo Group seeks to:
- Identify and manage transfer pricing risks proportionately
- Monitor changes in applicable tax laws and guidance
- Adjust arrangements where appropriate in response to legal or commercial change
Murzo Group reserves the right to restructure or discontinue arrangements where risk becomes unacceptable.
8. Confidentiality & Public Disclosure
Murzo Group treats transfer pricing arrangements as commercially sensitive.
- Detailed pricing methodologies, agreements, and data are not publicly disclosed
- Information is provided to tax authorities only where required by law or valid legal process
- Murzo Group does not publish voluntary tax transparency reports unless legally required
Nothing in this policy constitutes a waiver of confidentiality or legal privilege.
9. Enquiries & Challenges
In the event of enquiries or challenges by tax authorities:
- Murzo Group may engage professional advisers
- Responses are coordinated centrally
- Murzo Group may challenge or appeal assessments where appropriate
Engagement with authorities does not constitute acceptance of liability.
10. Legal Position & Limitations
This policy is a high-level governance statement and not a technical manual. It does not constitute tax or legal advice, does not create contractual obligations, and does not guarantee tax outcomes or authority agreement.
Nothing in this policy excludes liability that cannot be lawfully excluded.
11. Review & Updates
This policy is reviewed periodically and may be updated to reflect changes in law or international standards, business growth or structural change, and risk assessments and governance considerations.
