Our multidisciplinary team provides a range of planning, compliance, audit defense, and benchmarking services. In all cases, our professionals work to develop transfer pricing policies that are defensible, flexible, and in line with our clients’ overall tax planning strategies.
Transfer pricing classic services
- Assistance in preparation transfer pricing documentation (EUTPD);
- Assistance in case of transfer pricing tax audit;
- Preparation of transfer pricing policies;
- Assistance in Advance Pricing Agreements (APA) documentation and administrative procedures;
- Assistance Mutual Agreement Procedure (MAP) and documentation.
New transfer pricing, OECD - BEPS related, services | Country by Country reporting (CbCr)
The Country-by-Country Report requires aggregate tax jurisdiction-wide information relating to the global allocation of the income, the taxes paid, and certain indicators of the location of economic activity among tax jurisdictions in which the MNE group operates.
The report also requires a listing of all the Constituent Entities for which financial information is reported, including the tax jurisdiction of incorporation, where different from the tax jurisdiction of residence, as well as the nature of the main business activities carried out by that Constituent Entity.
Value Chain and Functional Analysis | Permanent establishment (PE) – Performing Value Chain and Functional Analysis to:
- Existence/Nonexistence of PE;
- Allocate functions, risks and assets used by the PE;
- Allocate profit per activity performed by the PE.
Business restructuring - Performing Value Chain and Functional Analysis to:
- Analyze economic substance of functions, risks and assets used by the new profile/s;
- Analyze existence for Intellectual proprieties or business transfer and the level of compensations, if case.
Economic substance (over form) of transaction – Performing Value Chain and Functional Analysis to determine economic substance of a transaction/s.
OECD / G20 BEPS definition: The economic substance of a transaction or arrangement is determined by examining all the facts and circumstances, such as the economic and commercial context of the transaction or arrangement, its object and effect from a practical and business point of view, and the conduct of the parties, including the functions performed, assets used and risks assumed by them.
Intellectual properties - Performing Value Chain and Functional Analysis and DEMPE analysis to determine economic owner of intangibles.
DEMPE analysis: Development, Enhancing, Maintaining, Protecting, Exploiting.
- Allocation on cost centers and adjustments according with value chain and functional analysis;
- Budgeting and true up.