Transfer Pricing
Multinational companies (MNC) must comply with specific requirements concerning transfer pricing. In recent years, transfer pricing has taken a more prominent position on the agenda of MNCs, as there has been an increase in both complexity and number of transfer pricing audits and disputes. We expect more of such audits and disputes in the coming years, as EU and local laws require greater tax transparency. Actively monitoring and documenting transfer pricing policies is vital.
With our vast experience in transfer pricing, both from a legal and economic perspective, the Atlas transfer pricing team can assist you in all aspects of transfer pricing – and as part of the WTS Global network – we can also offer our services globally.
Our transfer pricing services include:
Structuring
As a fully integrated tax firm, we advise clients on all aspects surrounding transfer pricing planning and design. We also take time to understand the markets in which our clients operate so we can advise on robust and sustainable strategies, accounting for all transfer pricing exposures and opportunities, including the level of risk that a company is willing to accept.
We assist our clients with setting up and converting business models, efficient transfer pricing structuring and intellectual property migration. We have a specialisation in tax valuations of corporate restructurings and perform valuations of companies, shares, financial assets and intangible assets.
With our extensive experience in successfully obtaining bilateral and multilateral advance pricing agreements (APAs), we can help prevent or limit the consequences of transfer pricing disputes.
Documentation
Base erosion and profit shifting (BEPS)-compliant documentation requirements, such as the Master and Local Files and Country-by-Country Reporting, are increasingly implemented around the world. Not only does this documentation need to adhere to more exhaustive detailed transfer pricing requirements (and stringent deadlines), but local tax authorities are also focusing more on the quality of the documentation.
We use a pragmatic approach which strives to balance the complexity and the size of the transfer pricing documentation. Using our smart transfer pricing software tools, we make our clients’ documentation more efficient and up-to-date whilst leaving ample time to focus on aspects that require further attention.
Implementation
The practice of efficient implementation and maintenance of transfer pricing models is continuously evolving. Being on top of operational transfer pricing offers efficiency benefits and limits the chance of unexpected additional costs not only from transfer pricing, but also concerning VAT and/or customs taxes.
Operational transfer pricing can thereby benefit greatly from automation and the use of technology. We assist our clients in automating their operational transfer pricing, and strongly believe that solutions should be tailored to the needs and complexity of each and every client.
Dispute resolution
Our team of transfer pricing specialists have specific experience in the area of dispute resolution and the mutual agreement procedure (MAP). With our in-depth knowledge and an approach based in both legal and economic argumentations, we can assist our clients in efficiently resolving transfer pricing audits and disputes, whether from an early stage or at court level. Internationally, we assist with resolving disputes through MAP under double tax treaties, the EU Arbitration Convention or the EU Dispute Resolution Directive. As part of the WTS Global network, Atlas can work across borders with other WTS member firms to resolve international transfer pricing disputes.
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