Industries
Years of experience have led us to deliver significant value to multinationals, business groups and local companies of different sizes and economic sectors. We know that each industry has its own dynamics, risks, business structures and competitive pressures. That is why our approach does not start from standard solutions, but from an economic, financial and tax understanding tailored to the reality of each company.
Industry
Mining and Natural Resources
Mining is the engine of the Chilean economy. We advise companies operating in commodity markets subject to international volatility and the different cycles of their business. The challenge lies in justifying intercompany prices when minerals move with the market, financing capital-intensive operations and withstanding SII scrutiny over commercial hubs abroad. We assist with price methodologies based on market quotations, determination of rates for financing large investments and negotiation of agreements with authorities that provide certainty in an environment of aggressive auditing.
Industry
Energy and Infrastructure
Renewable energy is the present. Behind every park or concession there are project finance structures, intercompany debt and guarantees that tax authorities scrutinize closely. The challenge is defending interest rates, guarantee margins and thin capitalization in long-cycle, capital-intensive projects. We contribute to the determination of market rates, valuation of concessioned assets and financial due diligence for entries, exits and refinancings.
Industry
Manufacturing Industry
Manufacturing is the heart of global value chains. Here coexist intercompany sales of goods, royalties for know-how and brand, and the key decision of characterizing the local operation: contract manufacturer, toll manufacturer or full manufacturer? The challenge is aligning the functional analysis with operational reality and reconciling transfer pricing with customs valuation. We assist with margin benchmarking, value chain alignment and the reconciliation between tax and customs requirements.
Industry
Retail and Distribution
This is an industry that generally faces thin margins, high volume and competitive pressure. The transfer pricing challenge lies in demonstrating that the local distributor captures a market return based on the functions and risks it actually assumes, while also sustaining payments for brand, franchise or group services. We provide comparability studies for distributors, royalty defense and economic analysis of profitability by channel, including e-commerce.
Industry
Logistics and Transportation
A business intensive in intragroup services. The challenge is setting market rates for shared services, intercompany leasing of fleet and equipment, and working capital financing — all in an industry with tight margins. We assist with the valuation of intercompany services, determination of leasing and financing rates, and profitability models by route or business unit.
Industry
Technology and Telecommunications
A large part of the value resides in intangibles and infrastructure. The challenge is attributing results according to the development, enhancement, maintenance, protection and exploitation of intellectual property (DEMPE analysis), setting defensible royalties and structuring cost-sharing agreements for R&D. In the telecommunications sector, financing of capital-intensive deployments is also a factor. We provide intangible valuation, royalty rate determination, cost contribution agreement design and financial advisory for infrastructure investments.
Industry
Health Sciences
The industry has a long value chain spanning pharmaceuticals, biotechnology and medical devices in highly regulated environments. These are businesses with long R&D cycles, molecule licensing and contract manufacturing. The challenge is valuing high-risk intangibles, allocating research costs across jurisdictions and sustaining the margins of distributors and contract manufacturers before increasingly coordinated regulators. We assist with IP valuation, cost-sharing structures for R&D and comparability studies across the entire chain, including manufacturing and distribution.
Industry
Agribusiness
This is a highly export-focused industry exposed to seasonality and the sale of perishable products. The transfer pricing challenge centers on justifying agricultural commodity prices, the role of commercial hubs and the financing of seasonal working capital. We provide pricing methodologies considering international markets, valuation of the commercial function and rate determination for financing, as well as applied economics to understand cycles and margins.
Industry
Mining and Natural Resources
Mining is the engine of the Chilean economy. We advise companies operating in commodity markets subject to international volatility and the different cycles of their business. The challenge lies in justifying intercompany prices when minerals move with the market, financing capital-intensive operations and withstanding SII scrutiny over commercial hubs abroad. We assist with price methodologies based on market quotations, determination of rates for financing large investments and negotiation of agreements with authorities that provide certainty in an environment of aggressive auditing.
Industry
Energy and Infrastructure
Renewable energy is the present. Behind every park or concession there are project finance structures, intercompany debt and guarantees that tax authorities scrutinize closely. The challenge is defending interest rates, guarantee margins and thin capitalization in long-cycle, capital-intensive projects. We contribute to the determination of market rates, valuation of concessioned assets and financial due diligence for entries, exits and refinancings.
Industry
Manufacturing Industry
Manufacturing is the heart of global value chains. Here coexist intercompany sales of goods, royalties for know-how and brand, and the key decision of characterizing the local operation: contract manufacturer, toll manufacturer or full manufacturer? The challenge is aligning the functional analysis with operational reality and reconciling transfer pricing with customs valuation. We assist with margin benchmarking, value chain alignment and the reconciliation between tax and customs requirements.
Industry
Retail and Distribution
This is an industry that generally faces thin margins, high volume and competitive pressure. The transfer pricing challenge lies in demonstrating that the local distributor captures a market return based on the functions and risks it actually assumes, while also sustaining payments for brand, franchise or group services. We provide comparability studies for distributors, royalty defense and economic analysis of profitability by channel, including e-commerce.
Industry
Logistics and Transportation
A business intensive in intragroup services. The challenge is setting market rates for shared services, intercompany leasing of fleet and equipment, and working capital financing — all in an industry with tight margins. We assist with the valuation of intercompany services, determination of leasing and financing rates, and profitability models by route or business unit.
Industry
Technology and Telecommunications
A large part of the value resides in intangibles and infrastructure. The challenge is attributing results according to the development, enhancement, maintenance, protection and exploitation of intellectual property (DEMPE analysis), setting defensible royalties and structuring cost-sharing agreements for R&D. In the telecommunications sector, financing of capital-intensive deployments is also a factor. We provide intangible valuation, royalty rate determination, cost contribution agreement design and financial advisory for infrastructure investments.
Industry
Health Sciences
The industry has a long value chain spanning pharmaceuticals, biotechnology and medical devices in highly regulated environments. These are businesses with long R&D cycles, molecule licensing and contract manufacturing. The challenge is valuing high-risk intangibles, allocating research costs across jurisdictions and sustaining the margins of distributors and contract manufacturers before increasingly coordinated regulators. We assist with IP valuation, cost-sharing structures for R&D and comparability studies across the entire chain, including manufacturing and distribution.
Industry
Agribusiness
This is a highly export-focused industry exposed to seasonality and the sale of perishable products. The transfer pricing challenge centers on justifying agricultural commodity prices, the role of commercial hubs and the financing of seasonal working capital. We provide pricing methodologies considering international markets, valuation of the commercial function and rate determination for financing, as well as applied economics to understand cycles and margins.