Transfer pricing, a hot topic
The Organization for Economic Cooperation and Development ("OECD") defines transfer pricing as "the prices at which a company transfers tangible property, intangible assets, or renders services to associated enterprises".
Transfer prices are thus the prices at which transactions take place between companies of the same group, but which reside in different countries. Such companies may be involved in R&D, manufacturing, distribution or sale of goods and merchandise, as well as in the provision of intra-group services. The issues are likely to range from cost-sharing among several companies in the group to the allocation of patent and trademark revenues.
Financial and reputational issues
In an international context marked by the will of the OECD and tax authorities to ensure that transfer prices are in line with the real value creation of each of the group entities involved in the transaction and the need to increase transparency on structures that have sometimes become complex, companies are facing significant financial and reputational risks. Regulations have been put in place and the control of transfer prices by tax authorities is thus more and more frequent.
As a result, the choice of the method used, its practice and the preparation of the required documentation require a multi-dimensional analysis and ongoing management that can be costly if proper tax considerations are not taken into account.
Our team of specialists is available to help you implement a transfer pricing policy that is adapted to your activities, strategy and objectives, while reducing tax risks. The expertise of our international network allows us to ensure the compliance and documentation of your transfer pricing policy and to guide you throughout your procedures with the tax authorities.
- Analysis of the existing transfer pricing policy of the group according to the legislation of the countries in which the entities operate;
- Support in the definition and implementation of a transfer pricing policy;
- Verification of the plausibility of the prices charged and comparability with similar third-party companies;
- Documentation of transfer prices according to the requirements of the tax authorities;
- Guidance and support in eventual negotiations with tax authorities;
- Support during restructurings and acquisitions, particularly in the case of the valuation of intangible assets during transfers between two countries