Hi all. Currently, I'm working at a B2B SaaS firm (Firm A), providing solutions for clients worldwide, including the subsidiaries of our Group. Transfer Pricing Challenge In the transfer pricing model, my firm must carefully manage the pricing of its services to ensure: 1. Tax Minimization: Firm A subsidiaries aim to minimize profits to reduce their corporate tax burden. This is achieved by inflating internal costs (e.g., software licensing, infrastructure costs) to reduce reported profits. 2. Benchmarking: For services like network infrastructure, data centers, and proprietary e-wallet software (which have no direct competitors in the market), pricing can be inflated without market benchmarks to justify the costs. 3. Tax Compliance: The strategy must demonstrate that the cost structures make sense from a regulatory perspective, especially in jurisdictions like Myanmar where Firm A has significant investments. Evidence Constraints To create a framework for standardized pricing, Firm A: 1. Use a Cost-Based Pricing Framework: This method is widely used in transfer pricing, especially when benchmarking data is unavailable due to a lack of competitors or comparable services. However, pricing SaaS products is inherently challenging, as they are difficult to value. 2. Document Competitive Advantage: For services that cannot be benchmarked (e.g., proprietary e-wallet software or network infrastructure), Firm A can demonstrate how these products offer unique advantages. However, we lack the information about other competitors price, and if we set our price higher, we need to prove the value proposition thoroughly during audit. Key Question Our goal is to maximize profit through transfer pricing to our headquarters in Vietnam by increasing the cost of all SaaS products. We must develop research-based evidence to proving our pricing during audits. The main challenge lies in identifying evidence: strategies and supporting data that effectively validate our B2B SaaS pricing.