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Transfer pricing

Today, transfer pricing is one of the main tax issues faced by groups. Whether your business is a high-growth start-up or an established multinational, you need to comply with transfer pricing rules. This means that you need to have transfer pricing documentation available based on which tax authorities can assess how conditions were determined and whether they reflect market circumstances.

The focus on transfer pricing has sharpened due to current developments within the OECD, the European Union and local jurisdictions. We see increasing numbers of countries implementing stringent transfer pricing documentation requirements. At the same time, businesses show concern with tax authorities vigilantly enforcing these new requirements in their quest for a larger share of the profits.

With our integrated tax & legal expertise and comprehensive transfer pricing knowledge we advise businesses in our main service areas Documentation, Planning & Strategy and Dispute Resolution.


Base Erosion Profit Shifting (BEPS)

The focus on transfer pricing has sharpened due to current EU developments.


Documentation

Often we hear that tax departments face issues in dealing with new transfer pricing documentation requirements such as Master File, Local File and Country-by-Country Reporting obligations. Our transfer pricing specialists help you to assess your documentation against stringent new requirements in our home markets (Netherlands, Belgium, Switzerland and Luxembourg). These experiences are used by our clients to roll out solid documentation standards in other jurisdictions. Our approach allows us to have a global impact with our local reach.

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Planning & Strategy

Feedback from clients shows that new regulatory developments force businesses to review their legal structures. We help your tax department in formulating sustainable transfer pricing strategies that are in line with your business whilst maintaining tax efficiency. Clients ask our advice on transfer pricing policies, building and converting business models and profit allocations into permanent establishments.

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Dispute Resolution

Clients experience the process of avoiding double taxation as very lengthy and complicated. With our integrated tax & transfer pricing practice, we are able to help you accelerate procedures and prevent double taxation. We also regularly assist our clients with audits and resolve (international) transfer pricing disputes both at an administrative and court level.

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News - 09 October 2019 - Global

The EC Approach towards State Aid in Tax Matters

In 2019 the first results from the European Courts coming in and some ongoing state aid investigations being closed without a finding of state aid.
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News - 24 September 2019 - Global

State aid update: EU General Court sets framework for the European Commission to enforce arm’s length transfer pricing under State aid rules

On 24 September 2019, the EU General Court upheld the Commission’s decision that Fiat received unlawful State aid from Luxembourg, and at the same time annulled...
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What others say about us

In­ter­na­ti­onal Tax Re­view

World Transfer Pricing: In both the Netherlands and Luxembourg we received tier-1 rankings. Our offices in Belgium and Switzerland received tier-2 rankings. (2020)