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Transfer Pricing

Transfer Pricing Where Judgement Matters

How value is attributed across a group, designed, documented and defended.

Services

Advice designed around the decision to be made.

Advisory

Advisory services, expert opinions and second opinions that support informed decision-making on complex transfer pricing matters.

Planning and strategy

Forward-looking planning that keeps intra-group transactions and their transfer pricing structure aligned with business objectives.

Policies

Design and implementation of transfer pricing policies, applied consistently across significant transactions.

Compliance

Preparation and review of intra-group agreements, Master Files, Local Files and Country-by-Country Reporting (CbCR).

Economic analyses

Economic analyses and benchmarking studies that determine appropriate remuneration between related parties, supported by access to relevant databases.

Valuations

Financial valuations for transfer pricing purposes, particularly for transfers of tangible and intangible assets, standalone or within a business restructuring.

Litigation

Support in audits and litigation, working closely with local law firms and tax advisers on the issues at hand.

Dispute avoidance

Mitigation of transfer pricing litigation risk through rulings, Advance Pricing Agreements (APAs) and cooperative compliance programmes.

Dispute resolution

Resolution of disputes that cannot be avoided, particularly through Mutual Agreement Procedures (MAPs) and arbitration.

Trainings

Customised training for companies and advisers on navigating transfer pricing challenges directly.

Expertise

Specialist depth across the transactions that shape cross-border value.

Transfer pricing for goods

Pricing structures that shape market competitiveness, supply chain resilience and shareholder returns, aligned with strategic objectives while remaining operationally and regulatorily sound.

Transfer pricing for services

Clear, defensible pricing of intra-group services that strengthens governance, improves resource allocation and withstands external scrutiny.

Transfer pricing for financing

Structuring and reviewing intercompany funding, loans, guarantees, cash pools and treasury arrangements, in a way that meets both commercial and regulatory expectations.

Transfer pricing for intangibles

Advanced economic and valuation approaches to price, manage and defend intangible transfers, including intellectual property and know-how.

Transfer pricing for business restructurings

Analysis of the implications of strategic reorganisations, quantification of their impact, and solutions that keep the transformation compliant.

Transfer pricing, customs and VAT

Integration of pricing policies with customs valuation and VAT frameworks, reducing risk, cost and complexity across the supply chain.

Transfer pricing and digital business transformation

Frameworks that capture the realities of digital value creation while preserving strategic and operational flexibility.

Permanent establishments

Identification and mitigation of permanent establishment exposure, enabling sustainable, well-structured cross-border operations.