Transfer Pricing
Experience Providing Global Transfer Pricing
The Altus Network has extensive experience providing global transfer pricing services. Transfer pricing has been and is likely to remain the most relevant tax related focus area for multinationals. Apart from the obligation to comply with local and / or international transfer pricing documentation requirements, transfer pricing has become key to successfully (re)structure business operations from a fiscal perspective as well.
As transfer pricing by nature involves cross-border transactions, having an international network of specialists is required to manage expectations from all countries involved in a transfer pricing exercise. Furthermore, as transfer pricing directly impacts a multinational’s operations from an economic, legal, tax and accounting perspective, these areas will have to be properly managed.
The Altus Network can assist multinationals in designing and documenting its global transfer pricing objectives with a close eye to the above-mentioned focus areas. This includes the offering of benchmarking services in relation to all types of inter-company transactions in all thinkable regions.
Types of Services
The Altus Network has a wealth of transfer pricing experience in relation to a wide range of industries. A brief overview of the types of services provided by the Altus Network includes:
- Traditional transfer pricing services such as the preparation of local/regional/global (Master File) documentation studies;
- Benchmarking analyses covering all types of inter-company transactions in all countries and regions worldwide;
- Design of tax/transfer pricing efficient regional/global structures in relation to intellectual property, tangible goods, procurement, (shared) services and loans;
- APA support whether unilateral, bilateral or multilateral;
- Develop cost sharing arrangements;
- M&A related services, both in the pre-M&A (such as the investigation and valuation of the transfer pricing related risks at the level of the ‘Target’) as well as post merger integration (such as the creation of tax/transfer pricing efficient supply chains after an M&A deal or the tax valuation of group companies);
- Financial services. The Altus Network services include design, documentation and benchmarking in relation to the Financial Services industry. As such the Network services banks, asset managers, REITs, insurance brokers and other providers of financial services;
- FIN 48. The Altus Network assists multinationals in managing local, regional or global controversy risks through effectively addressing a multinational’s alternative tax positions;
- Supply chain management in terms of design and transfer pricing related implementation of tax/transfer pricing efficient supply chains;
- Litigation support including business and intellectual property valuation, transfer pricing, accounting for book and tax purposes and valuation of contingent claims; and
- The provision of legal agreement templates covering inter-company transactions.
- The Altus Network offers a strong skill set combining expertise in economics, accounting and the law. The Altus Network has experience in a wide array of industries and knowledge of markets in many industrialized countries. The Altus Network has a thorough understanding of the competitive environment in different countries and expertise in the economic analysis of financial and non-financial information.
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