Transfer Pricing Services

The timely preparation of Transfer Pricing documentation has become a significant part of the compliance burden of SME’s and MNE’s. A Transfer Pricing specialist can support and optimize the process.

Operational Transfer Pricing is the practice of doing everything necessary to price individual intercompany transactions, and to accurately reflect transfer pricing policies in the administration and financial results of the parties involved.

In the strategic session, our experts gain a deep understanding of the composition and structure of your company, even in the most complex situations. Our team is specialised in understanding your business. The strategic session can focus on a specific topic you would like to focus on or your overall transfer pricing policy.

All transactions between related entities should be at arm’s length. This is a very important principle in international tax law. A transfer pricing analysis is required to determine the arm’s length price. The tp analysis will show whether there are opportunities and possible threats within the current transfer pricing policy.

The transfer pricing benchmark analysis is used to set and test your transfer pricing policy. Quantera Global assists your company in setting up a well-documented transfer pricing policy, by performing a full-fledged analysis, or help you update the current policy. The policy we set up will contain an at arm’s length remuneration, to prevent dis...

A transfer pricing audit is an investigation by a tax authority to ascertain whether a company is compliant with transfer pricing regulations. Tax authorities conduct such audits to ensure that their taxpayers are compliant and report sufficient profit.

Mutual agreement procedures (MAPs) can be used by taxpayers if they end up in a situation of double taxation due to a transfer pricing correction made by a tax authority.

Your company may have doubts about how to deal with controversy. Do you need a proactive controversy strategy or will a retroactive approach suffice, you might wonder.

Advance Pricing Agreements (APAs) are legally binding agreements between the taxpayer(s) and the tax authorities that are used to obtain prior clarity on the application of transfer pricing methods and/or rules for a particular set of transactions.

The increase in transfer pricing regulations and their growing complexity leads to an increase in transfer pricing controversies. Therefore, it is important to have a controversy strategy and to be prepared for different scenarios.

With the help of the Mutual Agreement Procedure (MAP), tax administrations resolve an increasing amount of (international) tax treaty disputes. However, there are still many dispute cases that remain unresolved.

The BAPA and MAPA process can be complex if you have limited experience with it. It is quite common to involve a Transfer Pricing specialist, not only for the technical side but also to support in how to handle the process most optimally.

At Quantera Global, we can provide a fresh perspective on certain topics. We provide new insights in a quick fashion and suggest solutions that have been proven to work in practice. As light or heavy as you wish, QG can be a sparring partner.

A good transfer pricing strategy is essential for any MNE. When your company is considering a new strategy, QG can provide support in this process. We can help to mitigate risks and seize opportunities.

As an independent transfer pricing firm, we are in the perfect position to provide an expert witness testimony / opinion on legal procedures concerning transfer pricing.

The master file focuses on describing the context in which intercompany transactions take place. The transfer pricing master file is prepared at group level. Quantera Global can take care of all your transfer pricing documentation including preparation of the master file. We can review whether your current documentation meets all guidelines and ...

Local files are an important part of the required transfer pricing documentation. Quantera Global can help your company set up solid documentation, such as local files. If your company is faced with (additional) documentation requirements, our advisors can support you.

Small and Medium Enterprises and start-ups often do not have to meet the master file and local file requirements but can prepare documentation in a free format. QG can support with a policy that meets the lower documentation requirements and provide internal and external clarity on the application of the transfer pricing policy.

An intercompany agreement (ICA) is a signed contract between two or more associated entities. Quantera Global can assist your company in drafting these agreements. And we ensure that all these important aspects are included in the agreement.

At QG, we work together with you to determine the level of compliance that best suits your company. We take into account your risk appetite, how you wish to structure your overall transfer pricing documentation, which files need to be prioritized and how to best organise the different roles in preparing the documentation.

Transfer pricing compliance is about meeting all regulations issued by tax authorities. To make sure your company is compliant QG offers a transfer pricing compliance overview service. This solution will help your company to make informed decisions with respect to your transfer pricing compliance and never miss deadlines.

Transactions can be described either in local files or prepared as such a separate transaction report for consistency and efficiency. The transaction report covers specific or one-off transactions. Quantera Global is an expert in preparing transfer pricing documentation, such as transaction reports.

Intercompany loans are loans from one entity to another, within the same company. This can offer your company multiple advantages, such as quickly shifting cash between entities or avoiding bank fees. QG can help to prepare all relevant documentation for intercompany loans.

Cash pooling is a method often used by multinational companies for cash management and intra-group financing. QG sets up proper transfer pricing documentation in combination with a robust transfer pricing policy for your cash pool activities.

This service QG offers includes the implementation and documentation of transfer pricing policies as well as financial transactions. Monitoring the correct transactions is also part of our service.

Forms of intercompany funding are cash pools, notional pooling and intercompany loans. With the help and support of Quantera Global, your company will have a well-documented and clear intercompany funding policy.

A financial guarantee is a guarantee provided by one entity on behalf of another entity against a third party-liability. The service QG offers is design and analysis of the financial guarantee, including the determination of the economic benefit derived from the guarantee, the effect of group membership and risk exposure of the guarantor.

Good governance is the process and system by which an organisation is controlled and operates. Different elements that are part of good governance are ethics, compliance, administration and risk management. QG offers board support, a transfer pricing control framework and awareness sessions.

As part of the OECD BEPS-Project, the OECD has introduced the Two-Pillar Solution as a way of updating key elements of the International Tax System, as the current tax systems are unable to cope with the globalised and digitised economy.

The country-by-country report is an important document for meeting transfer pricing documentation requirements. It is an annual requirement, including the related annual notifications. QG can help your company set up all required transfer pricing documentation, such as the CbCr.

The Dutch innovationbox regime is a preferential tax regime to stimulate R&D activities in the Netherlands. The main benefit of the Dutch innovationbox is that profits generated with innovative activities are subject to a reduced effective corporate income tax rate in the Netherlands.

Captive insurance may be relevant for large multinationals and refers to an entity whose insurance business is to provide (and/or to support with) insurance policies for the multinational group. The main advantage of this structure is to reduce fees to external insurance companies and to create synergy benefits.