We attend to all the needs of companies, law firms and tax advisors in relation to transfer pricing of cross-border group transactions.

Transfer Pricing Documentation

Preparation of mandatory transfer pricing documentation for  related-party transactions in line with the OECD Transfer Pricing Guidelines and the Corporate Income Tax Regulations:

  1. Group-specific documentation (“masterfile”)
  2. Specific documentation of the taxpayer (“localfile”)
  3. Annual Transfer Pricing Reporting (form 232)

Transfer pricing policy design

Design and implementation of transfer pricing policies aligned with a value-chain analysis for domestic and multinational groups.
Definition of policies that comply with the arm’s length principle through the correct application of the methodologies included in the OECD Transfer Pricing Guidelines, allowing compliance with the transfer pricing obligations in all the countries in which the group operates.
Assistance in the implementation of the new transfer pricing policies by adapting the group’s internal procedures as necessary. 

Advanced Pricing Agreements (APA’s)

Design, filing and negotiation of unilateral, bilateral or multilateral APAs before the tax authorities involved, which allow certainty on the acceptable transfer pricing policies for the cross-border intragroup transactions, thus avoiding tax risks and potential cross-border disputes in the area of transfer pricing.

Assistance in tax proceedings

In coordination with your tax advisors, defense of transfer pricing positions and policies in tax audit proceedings, domestic tax appealing procedures (economic-administrative claims and contentious-administrative appeals) or Mutual Agreement Procedures (MAP’s).
Preparation of expert reports on the valuation of related-party transactions.

May we help you?

We are specialists in the design, implementation, evaluation, documentation and defense of transfer pricing policies and national and international related operations. Do not hesitate to ask us your questions or problems.

Other services

Risk analysis & due diligence

Review of the compliance of your transfer pricing policies and practices with tax requirements relating to valuation methods, transactions’ supporting documentation, mandatory TP documentation and reporting filings.
In-advance detection of potential tax risks and preparation of recommendations, improvements and corrective plans.
Impact analysis of the measures introduced as a result of the OECD/G20 BEPS Project in your transfer pricing policies.

Benchmarking studies and comparability analyses

Preparing benchmarking studies and comparability analyses in accordance with the OECD Transfer Pricing Guidelines for inclusion in mandatory TP documentation or specific reports.
Determination of the arm’s length range for commercial, industrial, service, financial and intangible transactions, applying sophisticated economic analysis and the most complete databases on the market.

Country-by-Country Reporting

Assistance in the preparation of the Country by Country Reporting Filing (form 231) and in the criteria for the definition of the quantitative magnitudes to be reported.
Risk analysis in relation to the group’s transfer pricing policy and the information reported.

Tax Valutations

Determination of the market value for tax purposes of economic assets and transactions in accordance with the methods defined in tax and accounting regulations.

In-house training

Tailor-made training courses for your company or office staff on the application of transfer pricing rules, transfer pricing policies defined in the group, the application of internal procedures for documentation and support of intra-group transactions.

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