We assist clients in structuring and documenting intercompany transactions between related entities operating across different jurisdictions.
This includes ensuring that transactions such as the provision of services, sale of goods, and use of intellectual property are appropriately priced and supported in accordance with applicable transfer pricing rules.
Our work focuses on how intercompany arrangements function in practice.
This includes reviewing how functions, assets, and risks are allocated across entities, how transactions are structured and recorded, and how margins are determined and applied. We also assist in aligning these arrangements with the broader corporate structure and operational setup of the business.
We support both the implementation and documentation of transfer pricing positions, including coordination with external advisors where formal studies or documentation are required, and assistance in maintaining consistency over time as the business evolves.