Base erosion and profit shifting initiative (BEPS) Risk Analysis

  • Assessment of tax risks for transfer pricing purposes;
  • Management of tax risks for transfer pricing purposes;
  • Analysis, recommendations and implementation of transfer pricing policies and procedures;
  • Master file, Local file and Country-by-Country reporting;
  • Analysis, recommendations and implementation of transfer pricing documentation;
  • Analysis, recommendations and implementation of value chain management;
  • Relevance of advance pricing arrangements (APA);
  • Consulting on advance pricing arrangements (APA);
  • Documentation for advance pricing arrangements (APA).

Transfer pricing documentation

  • Preparation of transfer pricing documentation;
  • Assembling of transfer pricing documentation;
  • Analysis of transactions;
  • Economic analysis;
  • Comparability analysis optimization;
  • Functional analysis optimization;
  • Functions valuation for transfer pricing purposes;
  • Risks valuation for transfer pricing purposes;
  • Assets valuation for transfer pricing purposes;
  • Transfer pricing method optimization;
  • Optimized search for comparables;
  • Transfer pricing economic study and report.

Tax relief, dispute resolution and litigation

  • Mutual Agreement procedure;
  • Treaty-based returns and waivers;
  • Consulting through the CRA and IRS transfer pricing audit stage;
  • Consulting through the CRA and IRS objection and appeal process;
  • Voluntary disclosures;
  • Consulting through the Competent Authority process;
  • Economic expert study and report for the CRA and IRS objection and appeal process;
  • Transfer pricing economic study and report for the objection and appeal process;
  • Transfer pricing economic study and report for tax litigation;
  • Transfer pricing economic expert-witness for tax litigation.

Transfer pricing policies and risk management

  • Assessment of tax risk for transfer pricing purposes;
  • Management of tax risk for transfer pricing purposes;
  • Assessment of transfer pricing policies and procedures;
  • Design of transfer pricing policies and procedures;
  • Implementation of transfer pricing policies and procedures;
  • Evaluation of transfer pricing policies and procedures.

Advance Pricing Arrangements (APA)

  • Analysis of transactions;
  • Comparability analysis;
  • Relevance of advance pricing arrangements (APA);
  • Consulting and documentation on advance pricing arrangements (APA): prefiling meeting, request, submission, documentation, site visits, economic study and report, transfer pricing report;
  • Design and assembly of advance pricing arrangements (APA) request;
  • Design and assembly of advance pricing arrangements (APA) submission;
  • Economic expert study and report for advance pricing arrangements (APA) submission.

Value chain management for transfer pricing

  • Business system and operational transfer pricing;
  • Function valuations and strategic location;
  • Risk valuations and strategic location;
  • Asset valuations and strategic location;
  • Intangible valuation and strategic location;
  • Intragroup service valuations and strategic location;
  • Financial transaction (guarantee fees, insurance, cost and cash pooling, etc.) valuation and strategic location;
  • Business restructuring.