Transfer Pricing

Transfer Pricing

Transfer pricing governs every intercompany transaction. It is therefore crucial that any company implements a solid and compliant Transfer Pricing model. We provide Transfer Pricing support, ranging from planning to business restructuring support. Setting up and maintaining principal structures, writing intercompany agreements and tax audit preparation and defense. Transfer pricing can be very costly. Certainly since the last couple of years, authorities are focussing on transfer pricing and upcoming BEPS rules make it all even more complex. How do you handle Country-by-Country reporting? Ask any Big 4 consulting firm and you can be sure they can solve all your problems by implementing large costly projects. But do you always need an expensive BMW while a Citroen will also bring you save and cost efficient to your destination? I can help you to choose the right transfer pricing solution suitable for your company.

Business restructuring

Action 7 of the BEPS report (BEPS = Base Erosion and Profit Shifting) will make an end to the efficient way of using commissionaires in your company. This means that changing your current commissionaires to limited risk distributors for example could make sense. I can help you with this difficult dilemma. A lot of mergers take place, for example, in the Life Sciences and Pharmaceutical industry. Usually all of these companies have principal structures in Europe. Post-merger you suddenly have two principal structures.

What to do?

Are you a company (from the US, Latin-America or Asia) who wants to start doing business in Europe? If so, then you are confronted with many questions. In what country do you want to establish your European HQ? Switzerland or Ireland? Or perhaps Luxembourg? How can you make use of the European legislation? You need expert practical guidance when you struggle with these kind of issues. Advice from an in-house perspective.

Transfer Pricing support

  • Transfer pricing planning
  • Business restructuring
  • Conversion from commissionaire to limited risk distributor
  • Merging two or more principal structures
  • Designing and implementing Principal companies
  • Transfer pricing audit defense
  • Designing transfer pricing documentation processes
  • Negotiating TP rulings
  • Supporting Competent Authority procedures

BEPS preparation and defense

  • Analysing your current business set-up and preparing for the BEPS plans
  • Guiding your leadership regarding the BEPS plans
  • Modify your current inter-company agreements and align them with the TP documentation

Intercompany agreements

  • Analyse your current agreements and update them
  • Draw intercompany agreements BEPS proof
  • Aligning intercompany agreements with TP documentation

Tax audit support

  • Preparing your local finance/tax team for an upcoming tax audit (including role play)
  • Defining a tax audit strategy
  • Designing and implementing a global tax audit procedure