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Transfer Pricing

Today, transfer pricing has become much more than a matter of compliance for corporate taxpayers. It is currently the biggest tax issue facing multinational businesses as tax authorities seek to establish and enforce new guidelines and regulations.

With actions taken by the OECD, new regulations as well as more scrutiny from the tax authorities, we are seeing an overall increase in inspection (both in rigor and quantity) and a growing tendency towards litigation. Similar developments take place within the EU, like state aid procedures.

With this in mind you need a team that is already one step ahead of the latest regulations and fine points of law, is able to help you avoid litigation where possible (but ready to litigate when necessary), and can guide you through the increasingly detailed and often conflicting statutory transfer pricing codes in multiple jurisdictions.

At Loyens & Loeff, you can count on a multidisciplinary team of experts providing strategic transfer pricing advice that turns issues into opportunities – an important opportunity to simultaneously protect against double taxation, align inter-company pricing with business strategy – and ultimately support corporate development. 

Hands-on approach and bespoke answers

Multinational transfer pricing has tax advantages, but regulatory authorities frown upon using transfer pricing for tax avoidance. We can help you to operate optimally within the latest regulations. Benefit from our integrated tax and legal expertise and comprehensive transfer pricing knowledge. Our main service areas include:

  • Planning and strategy
  • Dispute resolution
  • Documentation

Transfer pricing is closely monitored within a company’s financial reporting and requires strict documentation in master files, local files and country-by-country reporting. If transactions are found to be inappropriately documented, you may incur additional expenses in the form of added taxes and penalties.

Our transfer pricing specialists can help you with your documentation. Our clients have often used the experience gained from such assistance to roll out solid documentation standards in other jurisdictions. Our approach allows us to have a global impact with our local reach.