Transfer Pricing
What do we mean by Transfer Pricing Services?
Approximately two-thirds of cross-border transactions occur between associated enterprises within the same multinational group. For multinationals and medium-sized enterprises alike, maintaining the pricing of intercompany transactions at an arm’ s length is an unavoidable necessity. International and regional organizations, as well as local tax administrations, require full compliance with the arm’s length principle. The significance of this aspect is reflected in the fact that an increasing number of Multinational Enterprise (MNE) groups view transfer pricing as one of the most significant risks to be managed, from both a reputational and a tax standpoint.
Our significant expertise in both the design of transfer pricing policies and assistance in litigation proceedings enables us to consistently address the most challenging issues associated with the commercial and financial relations existing in transactions between associated enterprises. We have access to the commercial and financial databases needed to perform a thorough comparability analysis to determine the most accurate economic results consistent with the application of domestic transfer pricing provisions.
What do we offer?
Transfer Pricing Compliance: TP Documentation
In a post-Base Erosion and Profit Shifting (BEPS) world, where tax administrations around the world are implementing the recommendations focused on transfer pricing (with a specific focus on Action 13 related to TP documentation and CbC reporting), Ecovis’ transfer pricing professionals assist taxpayers with home country and foreign documentation requirements by preparing transfer pricing documentation reports that analyze the arm’s length nature of their intercompany transactions. This includes supply of goods, the provision of services, and intercompany financial transactions. We can also assist multinationals with multiple foreign affiliates in preparing global documentation, including Country-by-Country reporting, in order to meet all of their documentation requirements in an effective manner.
Dispute Avoidance: Advance Pricing Agreements (APAs)
At Ecovis, our transfer pricing professionals assist clients with all aspects of defending their transfer prices before the tax authorities and with local audit teams before entering the confrontational environment of a transfer pricing audit. Our services relate to all the various phases of entering into an advance pricing agreement, with a focus on the pre-filing meetings, filing of the request and submission of the comparability study instrumental to enhance the transfer pricing model selected by our client. We provide assistance on APAs on a multi-jurisdictional scale.
Dispute Resolution: Examination Defense and Mutual Agreement Procedures
As the number of transfer pricing disputes continue to rise across every jurisdiction, there is a growing risk of economic double taxation. In such cases, Ecovis professionals provide invaluable assistance to taxpayers, helping them to activate mutual agreement procedures (MAPs) based on tax treaties or – at the European level – on the arbitration convention. These procedures enable taxpayers to engage with competent authorities all around the world.
Business Model and Supply Chain Optimization
In light of today’s dynamic global economic environment and the potential for legislative changes, it is becoming increasingly important to assess a multinational’s global business model. The Ecovis team of transfer pricing professionals offers high-quality, customized tax and business model transformation services.
At Ecovis, we work with clients to identify strategic opportunities for enhancing global tax and treasury planning. Our goal is to align the relationship between the taxpayer’s value drivers and income/cost streams, to improve their effective tax rate (ETF). This may include supply chain and intellectual property strategies, as well as global charges. Ecovis transfer pricing services facilitate the integration of operational and tax decisions, enabling clients to treat tax as another cost of doing business and make strategic decisions on an after-tax basis.
