TRANSFER PRICING SERVICES
Transfer Pricing, made defensible.
We assist multinational and cross-border businesses in establishing transfer pricing positions that are commercially grounded, rigorously documented, operationally embedded, and fully prepared for regulatory scrutiny.
30+
Years of experience
2011-Present
Established practice
STRATEGIC CONTEXT
Navigate complexity with confidence.
Tax authorities globally now demand unequivocal evidence that related-party pricing reflects economic substance and operational reality. We bridge the divide between complex technical mandates and the commercial priorities of modern cross-border enterprises.
This starts upstream with value chain analysis, operating model design, IP structuring, and intragroup financing pricing that anchor your documentation in commercial reality.
Regulatory Alignment
Continuous calibration with OECD guidelines and evolving local tax authority standards.
Commercial Substance
Pricing methodologies grounded in realistic value-creation and operating facts.
Defensible Evidence
Comprehensive, contemporaneous documentation ready to withstand direct inquiries.
CORE COMPLIANCE
Documentation that stands up to scrutiny.
Robust documentation establishes a coherent narrative between your group operating model, corporate transfer pricing policies, economic benchmarking, and local statutory filings.
Statutory Analysis
Local File
Entity-level examination of controlled transactions, functional risk profiles, tangible assets, and supporting financial results tailored to local tax administration requirements.
Group Architecture
Master File
An overarching global narrative articulating the multinational enterprise, core value drivers, intangible property stewardship, intercompany financing, and worldwide policy frameworks.
Global Transparency
Country-by-Country
Preparation, validation, and governance protocols for CbCR filings to ensure data reconciliation across tax returns, statutory financial statements, and local files.
Economic Substantiation
Benchmarking
Empirical economic comparability studies across industry databases to establish defensible arm's-length ranges for services, distribution, manufacturing, and royalties.
Operating Standards
Policy Documentation
Written frameworks establishing clear methodologies, intercompany calculation schedules, governance responsibilities, and operational controls to align day-to-day execution with formal tax guidelines.
PRACTICAL GOVERNANCE
Make the policy work in practice.
A compliant transfer pricing policy is ineffective if ERP systems, finance teams, and legal entities cannot execute it reliably month after month.
01
Implementation
Translating agreed methodology into practical workflows, chart of accounts mapping, and intercompany invoicing mechanisms.
02
Data Governance
Establishing defined data ownership, consistent calculation schedules, and clear audit-trail recordkeeping standards.
03
Controls
Building periodic true-up processes, variance tolerance checks, and automated oversight routines across global transactional flows.
04
Monitoring
Continuous tracking of corporate restructurings, M&A activity, regulatory updates, and operating margin variances.
DISPUTE RESOLUTION
Prepared for the questions that follow.
An audit is rarely won on theoretical tax law alone; it requires demonstrable facts, accessible economic rationale, and articulate coordination across all relevant jurisdictions.
Audit readiness assessments & evidence pack assembly
Advance Pricing Agreements (APA) and Mutual Agreement Procedure (MAP) support
Technical rebuttal development & dispute advocacy
Strategic alignment of economic models with operational substance