In an increasingly regulated international tax landscape, multinational groups must demonstrate that their intra-group transactions are conducted at arm’s length — not only for compliance purposes, but also to ensure that the transfer pricing model reflects the real economic substance and operational structure of the business.
Our transfer pricing advisory service combines strategic business understanding, economic benchmarking and international tax expertise to help companies navigate the full spectrum of transfer pricing requirements — from policy design to dispute resolution.
We begin with a thorough analysis of the business model and value chain, identifying where value is created, how functions and risks are allocated, and how intercompany flows should be structured. Based on this, we design or review the group’s transfer pricing policies, aligning them with OECD Guidelines and local tax requirements. Where necessary, we assist in drafting or updating intercompany agreements that support transactions involving goods, services, intangibles (IP), financial support, cost contribution arrangements, or secondment of personnel. In case of business restructuring or changes in value allocation, we assess the transfer pricing implications and help manage risk proactively, including exit charges where applicable.
Once the policy framework is clear, we conduct economic analyses and benchmarking studies to determine arm’s length pricing for transactions involving tangible and intangible assets, support functions, strategic services, financial arrangements and personnel allocation. Through access to specialised databases and robust comparability techniques, we produce defendable benchmarking reports and assist with the preparation of Master File, Local File and Country-by-Country Reporting (CbCR), ensuring full compliance with OECD BEPS requirements. Where relevant, we also evaluate and implement the Pillar 2 global minimum tax rules, analysing their impact on group taxation and operational substance.
In cases of potential controversy or double taxation, we assist in activating Mutual Agreement Procedures (MAP) between tax authorities to reach a resolution based on recognised international principles. For greater certainty moving forward, we support clients in negotiating Advance Pricing Agreements (APA), including cases involving transfer pricing methodology, existence of permanent establishments, attribution of profits and interpretation of EU directives. This proactive approach helps minimise disputes and provides a stable framework for future operations.
Our clients choose us because we combine technical transfer pricing expertise with a commercial understanding of how businesses actually operate. This allows us to deliver solutions that are not only compliant, but also aligned with long-term strategy and operational reality.
If you would like to assess your current transfer pricing exposure — or explore how benchmarking could enhance your group structure — we would be pleased to arrange an initial discussion.
