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.
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.
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.
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.
The EC Approach towards State Aid in Tax Matters
State aid update: EU General Court sets framework for the European Commission to enforce arm’s length transfer pricing under State aid rules
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)
Harmenvan Dam
Partner Tax adviserHarmen van Dam, tax expert, heads Loyens & Loeff’s International Tax Services practice group and the Transfer Pricing team. He focuses on corporate and international tax law.
T: +31 10 224 63 48 E: harmen.van.dam@loyensloeff.com
Markvan Casteren
Partner Tax adviserMark van Casteren is a partner in Loyens & Loeff’s International Tax Services practice group and a member of the Transfer Pricing team. From 2001 to 2005 Mark headed Loyens & Loeff’s New York office.
T: +31 20 578 54 33 E: mark.van.casteren@loyensloeff.com
PeterMoons
Local partner Attorney at law / Avocat à la Cour / Tax adviserPeter Moons, local partner, is a member of the Tax Practice Group in our Luxembourg office. He focuses on cross-border corporate tax advice for multinationals and funds, in particular private equity funds, their initiators and their investors.
T: +352 466 230 244 E: peter.moons@loyensloeff.com
NatalieReypens
Partner Attorney at LawNatalie Reypens is a member of the Loyens & Loeff International Tax Services Practice Group and heads the Belgian Transfer Pricing Team. She is a partner in our Brussels office. She focuses on corporate and international tax law.
T: +32 2 743 43 37 E: natalie.reypens@loyensloeff.com
BeatBaumgartner
Partner Attorney at law, Swiss certified tax expertBeat Baumgartner, attorney at law and Swiss certified tax expert, is a partner in our Zurich office. He focuses on Swiss and international taxation, M&A, financing and capital market transactions.
T: +41 43 434 67 10 M: +41 79 930 63 52 E: beat.baumgartner@loyensloeff.com
RogierSterk
Senior associate Tax adviserRogier Sterk, tax adviser, is a member of the Tax practice group.
T: T: +31 20 578 53 09 E: rogier.sterk@loyensloeff.com
LuciaSahin
Senior associate Tax adviserLucia Sahin, Dutch tax adviser, is a member of the international Tax practice group of Loyens & Loeff.
T: +31 10 224 63 01 E: lucia.sahin@loyensloeff.com