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;
• Design, analysis, recommendations and implementation of transfer pricing policies and procedures;
• Master file, Local file and Country-by-Country reporting;
• Assembly, analysis, recommendations and implementation of transfer pricing documentation;
• Design, 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

• Transfer pricing economic study, memorandum and report, as applicable;
• 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;
• DEMPE analysis for intangible property;
• Transfer pricing method optimization;
• Optimized search for comparables.

Audit management

• Mutual Agreement procedure;
• Treaty-based returns and waivers;
• Transfer pricing audit management and support;
• Transfer pricing economic study, memorandum and report for the audit;
• Objection and appeal process management and support;
• Competent Authority process management and support;
• Transfer pricing economic study, memorandum and report for the objection and appeal process;
• Transfer pricing economic expert-witness for tax litigation;
• Voluntary disclosures.

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 study and transfer pricing 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, costs and cash pooling, etc.) valuation and strategic location;
• Business restructuring and expansion;
• Subsidiary creation.