Context and Background
In 2024, Quantera Global was engaged by a stock-quoted US multinational corporation with a rapidly growing international footprint. The client had expanded through multiple acquisitions but had limited integration of transfer pricing (TP) practices across its entities. As a result, there was little consistency in how cross-border transactions were documented or evaluated.
This lack of internal alignment exposed the company to compliance risks, particularly in relation to intellectual property (IP) transfers, internal recharges, and the valuation of intercompany services. The firm’s global tax function recognized the urgency of developing a future-proof TP policy that was robust, compliant, and fully aligned with business operations.
Quantera Global’s Role and Strategic Contribution
Quantera Global took on a global TP advisory role for this transformation initiative. The engagement involved:
- Evaluating the client’s existing TP framework, identifying critical gaps and misalignments.
- Designing a comprehensive, forward-looking TP policy that incorporated best practices, business realities, and global tax authority expectations.
- Addressing legacy structures resulting from past acquisitions to create consistency across jurisdictions.
- Collaborating closely with the in-house tax and finance teams to ensure the new TP model was operationally feasible and sustainable.
The project called for a blend of technical precision and strategic insight – addressing IP-related risks, ensuring proper profit allocation, and embedding a culture of TP compliance throughout the organization.
Strategic Challenges
- The client’s accelerated growth through acquisitions had created a fragmented TP landscape with minimal integration.
- Multiple internal cross-border transactions had never been adequately addressed from a TP standpoint.
- There were latent risks tied to IP structuring and profit attribution, especially in jurisdictions with heightened TP enforcement.
- The company needed a globally consistent policy that was also adaptable to local requirements.
Outcome delivered
Quantera Global’s intervention led to:
- A new global TP policy framework that is robust, compliant, and fully integrated with the client’s operational model.
- Clear guidance on IP ownership, intercompany recharges, and service flows, reducing audit exposure.
- Improved internal coordination across business units, thanks to clear implementation tools and documentation.
- A significant step toward future-readiness, enabling the client to manage TP obligations confidently in over 40 jurisdictions.
Why This Matter Was Significant
This matter stood out for several reasons:
- It addressed a critical risk created by fast, acquisition-driven growth, which many modern MNEs face.
- It demanded a comprehensive redesign of TP policy, covering transactional and strategic dimensions.
- The project tackled complex, cross-border IP and integration issues, typically avoided or postponed.
- It reinforced Quantera Global’s ability to partner on global TP transformation, not just compliance.
By embedding structure where there was once fragmentation, the engagement enabled the client to move from reactive compliance to proactive TP governance – a transformative shift in how they manage tax risk and support business strategy.
Ready to turn post-acquisition fragmentation into one coherent, defensible TP policy?
Quantera Global helps multinational groups design and implement a future-ready global TP framework that aligns business reality with tax authority expectations. We blueprint IP ownership and returns, standardise intercompany recharges and service valuations, and embed clear profit allocation rules across jurisdictions. From gap assessment to policy redesign, implementation tools, training, and audit-ready documentation, we take you from scattered practices to consistent governance across 40+ countries, reducing controversy risk and unlocking smoother integrations.
Let’s align your global TP policy to your growth. Contact us here.