Transfer pricing compliance
International companies must comply with transfer pricing rules and documentation requirements governing intragroup transactions. Our team closely monitors global TP case law and administrative practice. For example, we analyse how foreign tax authorities approach comparability adjustments and in which circumstances the (internal) CUP method is accepted. The latter can reduce clients’ need for benchmark studies.
Turning transfer pricing compliance into strategic advantage
We translate these insights into concrete choices in TP methodology, benchmarks, and TP documentation. This creates a logical narrative supporting the selection of the TP method (e.g. TNMM, profit split or CUP), verified results and a traceable link to the financial statements. In this way, we provide Master Files (a general overview of the group), Local Files (local details of the group companies) and Country-by-Country Reporting (CbCR) that are audit-ready and in line with your actual business operations. Strategically defensible and usable in preliminary consultations, APA/MAP or, if necessary, in a dispute.
We are regularly asked to prepare Local Files and Master Files and to carry out or review benchmark studies. Our approach is emphatically practical, because most of the added value lies in the implementation. Before the end of the year, we identify any TP corrections and ensure that these can be incorporated into the annual figures and budget deliverables. Ideally, the corrective invoices (true ups and true downs) will also have been issued by that time, and intercompany agreements and ERP processing will be aligned.
Our focus is on the feasibility and anchoring of TP policy. We work closely with your finance team and, if desired, focus the assignment on knowledge building so that clients can apply TP policy independently. In our documentation, we avoid unnecessary benchmarks and generic, template-style TP files. Analyses are proportionate and based on facts. This ensures that corporation tax returns can be submitted without reservation and that TP positions are defensible.
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