Operational Transfer Pricing

Transfer pricing governs every intercompany transaction. It is therefore crucial for companies to implement a solid and compliant transfer pricing model.

We provide transfer pricing support, ranging from planning to business restructuring support. That includes providing a value chain analysis and preparing contemporaneous transfer pricing documentation. We also provide operational transfer support, ranging from writing intercompany agreements, managing tax audits, setting transfer prices, managing and supporting profitability processes, to writing transfer pricing policies and SOPs.

Transfer pricing can be very costly. Certainly since the last couple of years, authorities are focussing on transfer pricing, and upcoming BEPS rules make it all even more complex. How do you handle Country-by-Country reporting? If you ask any Big Four consulting firm to deal with it they'll manage, sure. But at what cost? The prices charged by these firms are often commensurate to their size - huge. It doesn't help that their clients often don't have in-house tax experts that can challenge the work performed. Eurofiscus does things differently: we believe in being efficient, timely and transparent.



Besides the advantage of saving a great amount of resources, using a smaller but highly specialised firm like Eurofiscus will also provide you with other additional benefits like our guaranteed personal attention:

  1. A call or email will immediately get you in touch with our most experienced transfer pricing specialist.
  2. Every product we deliver will have been looked over by our most senior specialist(s).
  3. Our advice is always tailored for your specific situation, no generic answers (see our VCA options).
  4. Avoid the downsides associated with a rapidly changing team.

We live and breathe transfer pricing, it is all we do. We work closely together with two other highly specialised transfer pricing firms, so you can always count on the support of around 30 transfer pricing specialists. Not only that, we also have a network of transfer pricing specialists spread out through Europe. We can reach out to these specialists in case you need specific local transfer pricing support.

Business restructuring

According to the OECD, business restructuring refers to the cross-border reorganisation of the commercial or financial relations between associated enterprises, including the termination or substantial renegotiation of existing arrangements. This often involves the centralisation of intangibles, risks or functions with the profit potential attached to them. At Eurofiscus we have a wealth of experience dealing with the various aspects of business restructurings, ensuring that companies are well prepared for possible scrutiny by tax authorities. Though "staying below the radar" is always preferable, during a business restructuring circumstances often do not allow for it. When that is the case, expert advice is absolutely crucial.

What to do?

Are you a company (from the United States of America, Africa or Asia) who wants to start doing business in Europe? If so, then you are confronted with many questions. What country is the best place for establishing a European HQ? Is it Switzerland, Ireland, or perhaps the Netherlands? How can you best apply European legislation to your advantage? To answer these questions, you need practical guidance from someone with experience solving exactly these kinds of issues. An expert, who can offer you advice from an in-house perspective. And that is precisely what we do!

General transfer pricing support

  1. Transfer pricing planning
  2. Headquarter location analysis
  3. Business restructurings
  4. Conversion from commissionaire to limited risk distributor
  5. Merging two or more principal structures
  6. Designing and implementing principal/headquarter companies
  7. Negotiating transfer pricing rulings
  8. Supporting Competent Authority procedures

Operational transfer pricing support

  1. Setting up transfer pricing policies
  2. Managing profitability issues
  3. Setting transfer prices
  4. Implementing transfer pricing in ERP systems
  5. Application of data management and analytics solutions for overcoming inconsistent transfer pricing data and process issues, and enabling effective and continuous implementation and monitoring of transfer pricing policies organisation-wide
  6. Analysing current intercompany agreements and updating them
  7. Drawing intercompany agreements BEPS proof
  8. Aligning intercompany agreements with transfer pricing documentation

Transfer pricing documentation

  1. Preparing master and local files in our highly automated documentation tool
  2. Country-by-Country reporting
  3. Preparing benchmark studies
  4. Setting up and documenting transfer pricing policies
  5. Analysing your current business set-up and preparing for the BEPS plans
  6. Guiding your leadership regarding the BEPS plans
  7. Modify your current inter-company agreements and align them with the TP documentation

Tax audit support

  1. Preparing your local finance/tax team for an upcoming tax audit (including role play)
  2. Defining a tax audit strategy
  3. Designing and implementing a global tax audit procedure
  4. Managing tax audits “on the ground”

Value Chain Analysis

  1. Tax business model review and optimisation
  2. Conducting a value chain analysis