Transfer pricing

What we do

Transfer pricing is most of what mid-cap groups get wrong, and the mistake usually stays invisible until the first informed audit. We work the full chain:

• Functional, asset and risk analysis of the relevant transactions
• Comparable search and benchmarking using the standard databases (Amadeus, Orbis, RoyaltyStat, Loan Connector)
• Local-file and master-file preparation in line with BEPS Action 13 and the country-specific add-ons
• Country-by-country reporting and the surrounding governance
• Advance Pricing Agreement (APA) drafting and negotiation, with a preference for bilateral APAs over unilateral where the volume justifies the process cost
• Defence in tax-authority enquiry and Mutual Agreement Procedure (MAP) cases

Transactions we see most often

Intra-group financing (cash pooling, term loans, hybrid instruments), intra-group services (management charges, cost-sharing arrangements post the 2024 OECD revisions), and intangible-property licences (the hardest segment after the BEPS Action 8-10 revisions and the DEMPE-functions analysis became mainstream).

Pillar Two interaction

We model the interaction between the historical transfer-pricing position and the new Pillar Two computations: groups that priced intra-group flows to keep their effective rate low are now seeing the floor hit them anyway, and the residual ETR-management headroom is much smaller than the pre-2024 modelling suggested. We re-baseline the analysis on a 15% floor assumption.

What we will not do

We do not produce documentation for a price that the underlying analysis cannot support. If the benchmarking returns a range that the client's pricing does not sit inside, we either re-price or we report the gap and let the client decide — but the file does not get dressed up.