Transfer prices must be tax-compliant, economically sound and properly documented.

We can advise you on the structure, analysis and documentation of your intra-group transfer pricing arrangements – from functional and risk analyses to advance pricing agreements and representation during tax audits. Our approach combines regulatory expertise with a pragmatic understanding of your business operations.

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Our services

  • Reviewing business activities / models relating to BEPS (OECD project concerning the reduction and transfer of profits) and assessing any risks

  • Assessing possible differences between the contractual and operational company organisation, including:
    • value chain (risks, functions and assets)
    • processes
    • group transactions
    • transfer pricing methods
  • Creating business models and group structures with solid substance
  • Implementing intellectual property rights and financing structures
  • Optimising the value chain
  • Preparing OECD-compliant local and master documentation
  • Defending transfer pricing documentation vis-à-vis the Swiss tax authorities in assessment procedures and during audits
  • Negotiating tax and transfer pricing agreements (Advanced Pricing Arrangements – APAs)
  • Coordinating transnational reporting projects (Country-by-Country-Reporting – CbCR)
  • Determining, quantifying, administering and monitoring transfer prices and tax risks taking current BEPS developments into account