Transfer Pricing

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DRTP Consulting’s transfer pricing services are relevant to any business with international activities. In the last 20 years, every country has implemented new transfer pricing rules aligned with the OECD Transfer Pricing Guidelines. Transfer pricing compliance costs are rising as the BEPS initiative effects are felt all over the world.

This regulatory landscape has created more and more tax audit activities and litigation. More than ever, state-of-the-art expertise is required to thrive in this new environment.


 

Transfer pricing documentation / BEPS rules documentation

DRTP Consulting performs all the steps necessary for transfer pricing documentation. DRTP Consulting assists clients in establishing functional and economic analyses of their intercompany transactions, covering every type of transactions:

  • Tangible good transactions
  • Intangible property transactions
  • Intragroup service transactions
  • Financial transactions such as intercompany loans, guarantees, cash pooling, etc.
  • Cost contribution arrangements

In the context of implementing the base erosion and profit shifting (BEPS) initiative, strong operational transfer pricing is required more than ever to address heightened compliance requirements. DRTP Consulting assists with the following tasks:

  • Analysis, recommendations and implementation of transfer pricing documentation
  • Master file, Local file and Country-by-Country reporting
  • Economic studies and database searches
  • Tax-efficient supply chain analysis and management
  • Analysis, recommendations and implementation of value chain management
  • Consulting on advance pricing arrangements (APA)
  • Documentation for advance pricing arrangements (APA)

Design: Value chain analysis and planning for transfer pricing

Competitive international trade requires more than ever strong operational transfer pricing. DRTP Consulting helps with the following tasks:

  • Business restructuring
  • Tax-efficient supply chain management
  • Relocation of functions, assets and/or risks
  • Risk transfer (in particular, derisking of operations)
  • Centralisation of procurement function
  • Centralisation of intellectual property
  • Functions valuation and strategic location
  • Risks valuation and strategic location
  • Assets valuation and strategic location
  • Intangibles valuation and strategic location
  • Intragroup services valuation and strategic location
  • Financial transactions (guarantee fees, insurance, cost pooling, etc.) valuation and strategic location
  • Customs valuation for intercompany transactions

Transfer pricing policies and risk management

  • Analysis, recommendations and implementation of transfer pricing policies and procedures
  • Country-by-country reporting strategic review
  • Assessment of tax risk for transfer pricing purposes
  • Management of tax risk for transfer pricing purposes
  • Assessment of transfer pricing policies and procedures
  • Design of transfer pricing policies and procedures
  • Implementation of transfer pricing policies and procedures
  • Evaluation of transfer pricing policies and procedures
  • Economic studies and database searches for transfer pricing policies and procedures

Advance Pricing Arrangements (APA)

Where it is deemed appropriate to obtain, in advance, acceptance of a company’s transfer pricing policies by the fiscal authorities interested by the transactions, DRTP Consulting assists with the following tasks:

  • Analysis of transactions
  • Comparability analysis
  • Assessing the relevance of advance pricing arrangements (APA)
  • Consulting and documentation on advance pricing arrangements (APA): prefiling meeting, request, submission, documentation, site visits, economic study and report, transfer pricing report
  • Design and assembly of advance pricing arrangements (APA) request
  • Design and assembly of advance pricing arrangements (APA) submission
  • Economic studies and database searches
  • Economic expert study and report for advance pricing arrangements (APA) submission

M&A-related transfer pricing valuation and advice

M&A transactions often have very important transfer pricing implications.  DRTP Consulting can help with the following tasks:

  • Business restructuring valuation and planning
  • M&A integration support (for transfer pricing purposes)
  • Asset transfer documentation, analysis and planning
  • Buy-side/sell-side negotiation support

 

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