Transfer Pricing and International Taxation
From startups to large multinational groups; from basic documentation to defense in complex controversies over intangibles.
Periodic Obligations and Documentation
We prepare and maintain transfer pricing documentation to comply with local requirements and OECD standards: Transfer Pricing Study (Local File), Master File and CbCR (when applicable). We conduct the functional analysis (FAR), define transaction characterization and support margins with robust benchmarking, leaving traceability and evidence for audits.
Controversies
We provide comprehensive support in transfer pricing audits, requests and examinations, from strategy to technical response. We build the economic narrative, defend comparables and methods, quantify impacts and propose alternatives to mitigate adjustments.
Value Chain Alignment
We advise on aligning the business value chain with tax policies that ensure consistency between the form, substance and economic reality of intercompany transactions within and outside the country.
MAP and APA Negotiation
We advise on preventive mechanisms and double taxation elimination, including Mutual Agreement Procedures (MAP) and Advance Pricing Agreements (APA) where available. We assess feasibility, define the technical case, prepare documentation and support negotiation with authorities, seeking tax certainty, risk reduction and margin stability.
Planning, Operating Models and Restructurings
We design transfer pricing policies before executing relevant transactions: goods, services, intangibles and intragroup financing. We define roles and risks, select methods, set target ranges and adjustment mechanisms, and align contracts with actual operations. The result: informed decisions, reduced exposure and a defensible narrative over time.
Adjustments and Double Tax Treaties
We advise on the use of double taxation legislation to recover cross-border transfer pricing adjustments. An adjustment in one jurisdiction should bring a corresponding adjustment in the counterpart's jurisdiction in compliance with applicable treaties.
Do you need transfer pricing advice?
Let's talk about your challenges. Our team is ready to support you.