Our Services

Transfer Pricing Documentation & Compliance

We assist multinational groups in preparing fully compliant transfer pricing documentation, tailored to the requirements of each jurisdiction in which they operate.

Services include:

  • Local File preparation (OECD-compliant)
  • Master File drafting (business overview, intangibles, financials, value chain)
  • S. transfer pricing reports (IRC §6662 documentation)
  • Country-by-Country Report (CbCR) review and consistency checks
  • Industry- and region-specific reports
  • Documentation for low-value-adding intra-group services

Benefits:

  • Compliance with local tax authority expectations
  • Risk mitigation in audits

Strategic alignment of intercompany pricing with functional reality

Transfer Pricing Planning & Policy Design

Beyond compliance, we help clients proactively structure and evaluate their intercompany arrangements.

Services include:

  • Design of intercompany pricing policies for goods, services, IP, and financing
  • Supply chain optimization through TP modeling
  • Global alignment of functions, assets, and risks
  • Restructuring analysis (e.g., conversion to limited-risk distributor or contract manufacturer)
  • Implementation support (contracts, internal guidance, ERP mapping)

Use cases:

  • Business expansions or reorganizations
  • New IP development or migration
  • Centralization of procurement, logistics, or support functions

Advance Pricing Agreements (APA)

We support clients in preparing, evaluating, and negotiating unilateral, bilateral, or multilateral APAs.

Services include:

  • Pre-filing consultation strategy
  • Functional and economic analysis for APA proposals
  • Preparation of full APA submission package
  • Support during tax authority meetings and negotiations
  • Documentation of critical assumptions and renewal procedures

Why it matters:
APAs provide certainty and avoid costly disputes. Our role is to ensure your APA is technically sound and defensible.

Valuation of Intangibles, Business & Transactions

We perform robust, defensible valuations of intangible assets and business operations for tax, legal, and strategic purposes.

We value:

  • Trademarks, patents, brands, software, customer lists
  • Business units or legal entities (M&A, spin-offs)
  • Intra-group licensing arrangements
  • IP migrations and cost-sharing buy-ins
  • Exit charges and demergers (DEMPE analysis)

Methods applied:

  • Discounted Cash Flow (DCF)
  • Relief-from-Royalty
  • Comparable Uncontrolled Transactions (CUT)
  • Market multiple analysis
  • Profit split models aligned with OECD/IRS standards

Benchmarking & Economic Comparability Analysis

Our benchmarking studies support arm’s length pricing of intercompany transactions by identifying reliable comparables.

We conduct:

  • TNMM / CPM benchmarking
  • CUP studies (royalty rates, interest rates, license fees)
  • Interest rate benchmarking for intra-group loans
  • Asset management fees and cost allocations
  • Selection and application of tested parties, profit level indicators (PLIs), and adjustments

Tools & databases:
Amadeus, Orbis, RoyaltyStat, ktMINE, Bloomberg, LoanConnector, S&P Capital IQ

Dispute Resolution & Audit Support

We help companies manage and resolve transfer pricing audits and disputes by preparing technical responses, rebuttal reports, and strategic defense positions.

Services include:

  • Audit risk assessments
  • Response to tax authority information requests (IDRs, ESAPs, etc.)
  • Expert economic reports and opinions
  • Assistance during tax litigation (e.g., depositions, witness reports)
  • Economic support in Mutual Agreement Procedures (MAP)

Strategic International Tax Advisory

We bridge the gap between transfer pricing and international tax strategy, supporting clients in optimizing global tax structures.

Key areas:

  • Entity rationalization and operating model redesign
  • IP holding structures and licensing chains
  • Support for Pillar One and Pillar Two impact analysis
  • Substance-based analysis (BEPS Action 5)
  • Withholding tax planning and treaty access analysis

Support for Internal Teams & Stakeholders

We frequently partner with in-house tax teams, CFOs, and legal counsel to build knowledge and capacity.

What we offer:

  • Transfer pricing health checks and risk reviews
  • Internal training workshops (TP fundamentals, CbCR, DEMPE, etc.)
  • Board and executive-level briefings
  • Assistance with tax governance and internal controls related to TP

Transfer Pricing Policy Development

We help you establish clear and defensible transfer pricing policies aligned with your business strategy and industry best practices.

Benchmarking Studies & Economic Analysis

Our experts conduct thorough analyses to identify arm’s-length prices for your specific transactions (tangible, services, intangible and financial).

Transfer Pricing Documentation Preparation

We can assist you in preparing comprehensive documentation that meets IRS requirements and supports your transfer pricing positions.

Intangible Property Valuation

We help you accurately value intangible assets like trademarks and patents for transfer pricing purposes.

State Transfer Pricing

We provide guidance on complying with increasingly important state-specific transfer pricing regulations.

Transfer Pricing Audits

Our experienced team can support you during IRS audits, advocating for your position and minimizing potential tax adjustments.