Transfer Pricing

Transfer Pricing (“TP”) has become a significant issue for multinational enterprises over the last few decades. It has become more complex than ever before and for most multinationals, TP is now the number one tax priority. The area of TP is continuing to evolve.

What services can we provide?

• designing appropriate and defensible policies and performing thorough analyses; 
• preparing and updating legally required documentation, including Country-by-Country reporting, master files and local files;
• advising on the use of mutual agreement procedures (“MAP”) - Tax Litigation, and the EU Arbitration Convention to resolve any double taxation - EU Tax;
• feasibility studies and impact assessments for IP transfers and business reorganisations;
• determining and substantiating arm’s length remunerations for all kind of business activities and transactions; 
• concluding APAs and ATRs with the Dutch tax authorities working closely together with our State aid experts, to ensure sound rulings and avoid recovery risks; and
• providing valuation services, ranging from equity and intangible asset valuations to value-based management (“VBM”) services (e.g. value driver assessments and cash-flow sensitivity analyses).

1. tax and TP strategy
2. relationship with the tax authorities
3. quality of analyses