Transfer Pricing

We are a full scope transfer pricing service firm, with global reach, meaning we have adequate competencies, capabilities, capacity and experience to drive consent:

  • Across all topics:
    Tangible assets > Services > Intangibles > Financing
  • Across the full life cycle of a transfer pricing policy:
    Assess > Design > Implement > Document > Sustain
     

Yet, we are confident to say that we have built a true expertise in complex specialist matters, such as:

  • In the fields of:
    • Intangibles, and
    • Financial transactions / treasury
  • Across the full life cycle of a transfer pricing policy:
    • Assessments – TP SWOT Reviews
    • Redesigns – Business restructurings
    • Implementation – TP control frameworks
    • Documentation – Business case development
    • Sustain – Procedural aspects, in close collaboration with Tiberghien tax lawyers, including litigation

Below, you may find a more detailed overview of our transfer pricing service offerings, and please also consider our featured solutions section.

TP Life Cycle

Subject matters in transfer pricing include, starting with our special expertises:

  • INTANGIBLES
    • Pricing – Valuation
    • Options Realistically Available – Business case / rationale
    • Licensing – Royalties
    • IP incentive schemes
    • R&D organization – Cost Contribution Arrangements
    • Business restructurings – Indemnifications
    • Location savings analysis
  • FINANCE & TREASURY
    • Loans – Credit facilities
    • Guarantees
    • Treasury center
    • Factoring – Invoice discounting
    • Cash pooling
    • FX risk management
  • SERVICES
    • Low Value-Adding Services – Core business services
    • Shared Service Centers – Cost sharing arrangements
    • Shareholder activities – Stewardship
    • Cost allocation systems
    • Economic Interest Groupings
    • Stock option plans
  • TANGIBLE ASSETS
    • Raw materials and direct spent – WIP – Finished goods
    • Procurement structures
    • Manufacturing – Sales & Distribution
    • Capital investments – Leasing
  • OTHER
    • Attribution of profits to PEs
    • Financial Services TP