Governance, design & strategy

• Board support
  • We prepare or conduct strategic meetings with the board to provide an overview of the Transfer Pricing landscape. We outline how this may affect your company and advise you how to organize and prepare for the underlying challenges.
• Transfer Pricing control framework
  • We prepare a structured approach towards Transfer Pricing that suits the size, complexity and risk appetite of your company and sets the appropriate controls.
• Awareness sessions
  • We provide Transfer Pricing awareness sessions to selected groups of colleagues. These sessions help your team to identify potential Transfer Pricing risks.

Transfer Pricing design should support your business and must be simple and compliant. In addition, it should make use of available tax incentives. We prepare the design that best suits the company. We always look at the larger picture and take the long-term vision of the company into account. The depth of our analysis will depend on the size and complexity of the company or division. Our analysis typically increases business insights, saves administrative efforts, limits tax risks and may have a positive impact on the effective tax rate.

When you are contemplating a new strategy for your company, we can provide support in this process. With the help of our Transfer Pricing analysis of your company and our experience with all sorts of strategies (of both small and large MNEs in various industries), we can give you valuable insights. For example: how to allocate responsibilities and set Key Performance Indicators (KPIs). In addition, involvement in this process allows us to simultaneously address the best Transfer Pricing design for the new strategy.

In our strategic sessions we discuss in-depth on selected Transfer Pricing topics and brainstorm on the most suitable approach to the topics for your company. We refer to our brochure for more detailed information.

Many of our clients are experiencing various developments in their business. They like to have a sparring partner who understands their company and position and who can provide pragmatic advice in a quick and efficient way by just addressing the needs of the company. We enjoy being a sparring partner and are often asked as such.

We advise clients on the use or transfer of intangibles and potential onshoring.

A CCAs is a specific Transfer Pricing methodology that might well be applied to deal with intangibles. Although this methodology is relatively complex it can provide substantial benefits such as avoiding withholding tax.

If an intangible is transferred, intercompany specific rules apply. Our specialists in this field address the valuation. Depending on the case we can work together with registered valuators to provide you a full service in this field.

When intangibles of one entity are used by other entities, a remuneration methodology needs to be set. A common approach is applying a license fee which needs to be supported by a benchmark study. We offer support in both determining the appropriate methodology as well as the benchmark study itself.

Many tax authorities, including the Dutch tax authorities, offer a beneficial regime for profit that originates from Research and Development (R&D) activities. Certain requirements must be met to be eligible for such regime. Once eligible it must be determined which part of the profit falls under the beneficial regime. The outcome depends on how well the innovative character can be substantiated. Our specialists can assess whether your company is eligible and can prepare the appropriate substantiation. In addition, we work together with partners for related optimization such as fiscal discounts on (wage) costs.

It will have a positive effect on the (partial) sale of your business if Transfer Pricing affairs are in order and when this is substantiated by a third-party. In addition, if only part of a business is sold you may want to check whether that will have an adverse Transfer Pricing impact on your remaining business.

You don’t want unpleasant surprises after an acquisition. We can check whether the Transfer Pricing system applied in the past is defendable and if documentation is in order. Should this not be the case, we can indicate the impact on your business. We can also analyse whether the integration of Transfer Pricing policies after acquisition may provide for specific challenges.

When you acquire a business, the Transfer Pricing system applied may not be in line with the Transfer Pricing system applied in your current business. We provide support to defend these Transfer Pricing systems and advise you on how to align these Transfer Pricing systems along with the business integration.

Restructuring your business will probably have Transfer Pricing implications. We provide in this respect support in the strategy on how to deal with restructurings, valuations and related documentation such as defence files.