Transfer Pricing

TRANSFER PRICING

Rapidly growing cross-border trade has made transfer pricing a key challenge for internationally operating businesses. Coupled with a worldwide rise in scrutiny from tax authorities, increased attention in the public domain and an ever changing regulatory environment, transfer pricing has become a key focus area for organisations worldwide.

In today’s world, transfer pricing risks such as tax adjustments, interest and penalties and, most importantly, reputational risks, continue to be primary concerns for C- level executives.

The Alter Domus’ transfer pricing team offers  a cooperative, long term, solution focused working relationship, helping you navigate the rapidly evolving global transfer pricing landscape, to deliver practical and cost efficient solutions with a quick turn-around.

OUR CREDENTIALS

  • PE group with HQ in Finland, subsidiaries in the Nordic region and Fund structures through Luxembourg
  • Benchmarking analysis of the determine the advisory fees paid by the Luxembourg ManCo to the Swedish Advisory company.
  • Investment firm specialising in public and private corporate credit with Assets Under Management approximately USD 37 billion
  • Determination of the appropriate remuneration to be realised with respect to the main functions performed in the value chain, in particular with respect to:
    • Provision of low-value added services
    • Loan origination services
    • Investment management services

Example 1:

  • PE group with Asset Under Management of approximately USD 65 billion
  • Determination of the arm’s length remuneration to be realised by the Luxembourg entities in the structure (more than 100) with respect to their intragroup financing activities
  • Preparation of interest rate benchmarking analyses

Example 2:

  • RE group with assets of approximately EUR 4.8 billion
  • Determination of the arm’s length remuneration to be realised by the Luxembourg entities in the structure with respect to their intragroup financing activities
  • Preparation of interest rate benchmarking analyses

Example 1:

  • Investment company with over EUR 5 billion of AUM
  • HQ in Belgium and entities across Europe and Asia
  • Preparation of a Master File for the Belgium HQ and Local Files for the entities in Belgium, Luxembourg and Singapore 

Example 2:

  • Group active in the transport and logistic sector with a  turnover of approx. EUR 700 million
  • HQ in Belgium, subsidiaries in other European countries
  • Preparation of a Master File for the Belgium HQ and Local Files for the entities in Netherlands, Belgium and Germany


OUR SERVICES

Alter Domus’ network of transfer pricing professionals offer you comprehensive transfer pricing solutions tailored to your needs, leveraging our multi-jurisdictional expertise and mix of in-house and external advisory experience, to support you with pragmatic and efficient transfer pricing advice. Most notably.

  • Development of transfer pricing documentation 
  • Development of Master File / Local File
  • Country by Country reporting (CbCR) notification and guidance
  • Interest rate and margin benchmarking
  • Management fee analyses
  • Royalty rate analyses
  • Guarantee fee calculations
  • Tax authority engagement
  • Due diligence support
  • Review of tax returns (for Transfer Pricing)
  • Substance analyses (Luxembourg)
  • Global cost sharing arrangements
  • Benchmarking analyses 


Offices and Jurisdictions covered

The Alter Domus Transfer pricing covers multiple offices in Europe and spans accros a multitude of jurisdictions.
Our geographical coverage on a map

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