Transfer pricing

A global view on a business-critical, fast-evolving issue. 

Organisations that span international borders are increasingly facing complex regulatory and tax issues in the different jurisdictions where they operate. Transfer pricing is at the top of the tax priority list for many mid-sized and large businesses, with an outsized impact on and business units. We offer a range of solutions for transfer pricing management so you can ensure compliance with local regulations.

Our approach

There is greater scrutiny of transfer pricing the world over. Only a global, multi-layer approach can bring simplicity to this fast-evolving issue. Our global partnership in more than 100 countries provides the vital expertise in tracking developments such as new legislation and court/tribunal rulings in each jurisdiction, through direct contact with our transfer pricing experts who have deep industry know-how and the local and international expertise necessary.

Our International Transfer Pricing Community brings together specialists from across disciplines, including economists to help with value chain analysis: a vital tool to align transfer pricing with economic value creation and establish transfer prices for intangibles. Data is the foundation for a robust transfer pricing regime. Recognising this, we have created databases and tools such as a cloud-based system to ease reporting under the EU’s DAC6 directive.

Our service begins with a diagnostic risk assessment that seeks to highlight areas for savings, as well as exposure. We then work closely with you to make sure you can meet your documentation obligations and optimise your tax positions.

Our services

• Strategic advice on all aspects of transfer pricing;
• Master file, local file and country by country reporting;
• Economic analyses, including financial transaction benchmarks, and license benchmarks;
• Tax audits, mutual agreement procedures;
• Value chain analysis and transformation;
• Cash pools and other integrated group wide financing systems;
• Transfer of functions, valuation of transfer packages, exit taxation;
• Valuation of hard to value intangibles.

Our people

Our international team consists of experienced tax specialists and transfer pricing experts with country and sector specific tax and industry knowhow, accountants and economists, which ensures that we can provide, develop and implement customised transfer pricing solutions that fit with our clients’ commercial and tax strategies.

In Luxembourg, our team is composed of transfer pricing experts with extensive experience in financial transactions. Accompanied by Luxembourg and international tax experts, we have been providing services to alternative investments and financial services clients for many years, developing a trust relationship through high quality and tailormade advice.

Our tools & solutions

With Transfer Pricing Genie, we offer a digital transfer pricing documentation solution that is a more efficient approach to increase transfer pricing processes. We also offer database access, including Bloomberg and RoyaltyStat, as well as the automatic transmission of country by country reports (CbCR) and data exchange through our Signals tool.

Our operational TP strategies are designed to optimize tax positions and ensure compliance with local regulations. Through our expertise in aligning transfer pricing with value chains and economic value creation, we help establish transfer prices for both tangible and intangible assets, minimizing risks associated with intercompany transactions. Compliance with Transfer Pricing Guidelines issued by organizations such as the OECD is paramount for multinational enterprises. We provide comprehensive guidance on adhering to these guidelines, assisting in the preparation of robust TP documentation that incorporates benchmarking and economic analysis to support your positions during tax audits.

Effective risk management is essential in navigating the complexities of transfer pricing. Our team identifies potential areas of exposure and implements strategies to mitigate risks associated with Base Erosion and Profit Shifting (BEPS) and other regulatory challenges. Transparent financial reporting is crucial for demonstrating compliance with TP regulations and fostering trust with tax authorities. We provide strategic advice on incorporating transfer pricing considerations into your financial reporting processes, ensuring accurate disclosures of intra-group transactions and related party dealings. Our support extends to preparing country by country reports (CbCR) and digital transfer pricing documentation, leveraging cutting-edge technology to streamline reporting requirements and enhance compliance.