Transfer Pricing

Transfer pricing is at the core of international trade and a vital issue for multinationals. Countries worldwide are today scrutinising inter-company pricing strategies and enacting rules to ensure appropriate allocation of income and assets among the various tax jurisdictions in which a multinational operates.

Our services

Our transfer pricing team provides integrated transfer pricing services, both from an advisory and a documentation side. Our transfer pricing economists perform the relevant economic analysis to establish a sound transfer pricing documentation. Our services include the following:

• Advising on compliance with transfer pricing regulations.
• Review of controlled transactions, providing a transfer pricing risk assessment, including potential solutions.
• Conducting a transfer pricing due diligence.
• Providing OECD compliant functional and risk analysis.
• Conducting benchmarking studies and drafting transfer pricing documentation for all types of inter-company transaction including the provision of financing, management, distribution and other services, manufacturing activities, licensing of intellectual property rights, interest rates and guarantee fees.
• Review of the legal documentation regarding controlled transactions from a transfer pricing perspective.
• Drafting and filing of unilateral, bi- or multilateral advance pricing agreement (APA) applications and liaising with the Luxembourg tax authorities.
• Drafting and filing of mutual agreement procedure (MAP) requests and liaising with the Luxembourg tax authorities.