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:

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