Panoramic: Automotive and Mobility 2025
Transfer Pricing
In today’s environment, transfer pricing cuts across all aspects of driving value in a business. It is a key strategic tool that must be managed and implemented effectively.
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That’s where we come in. We do it right. With a combination of accountants, economists, and people schooled in business, we know how to work-out what drives value in a business and then put a price on it.
Our team of transfer pricing specialists brings a wealth of in-house, advisory, and tax authority experience. We focus on strategy and planning, providing solutions that are insightful, robust, and pragmatic. Whether you are undertaking a business reorganisation, expanding into new markets, adopting new business models, have assets that need valued or integrating an acquisition, we have the right team for you. Oh, and we implement too, so with a team of lawyers standing behind us we can do all the legal stuff as well in offices all around the world.
No agenda. No baggage. Just good advice.
Representative experience
Advised on and implemented a Procurement Hub and IP Hub for a global food multinational, spanning over 15 jurisdictions and including negotiating with relevant authorities and legal entity restructuring.
Advised on supply chain optimization and the creation of a single hub to house IP, procurement and sales related activities for a global business spanning multiple jurisdictions and over a hundred entities.
An extensive valuation exercise for a global medical devices and technology group that was undergoing an extensive legal entity restructuring program including valuations in over 10 jurisdictions.
Conducted a strategic review of transfer pricing for a household goods group relating to procurement operations in Hong Kong and China, and advice on the approach to settling a long-standing dispute.
Drafted expert opinions on a number of cases involving allegations of value-shifting through non-arm's length transfer pricing.
Helped a Japanese car manufacturer with a corporate tax and transfer pricing audit in Italy, and investigations of alleged tax offences on disregarding a commissionaire structure, and an alleged "hidden branch".
Implemented a dual principal structure for a global beverage company with operations in over 30 countries, from feasibility to implementation.
Integrated three acquisitions into an existing centralized business model covering numerous jurisdictions.
Numerous brand valuation on M&A transactions (examples include working for the seller and the buyer).
Numerous consumer brand valuations for a LATAM group, including centralisation of same in a Principal company in Panama.
Provided a global telecoms group with an expert opinion regarding application of the arm's length principle to credit rating and loan pricing. Prepared report and response. Tribunal decision aligned with opinion.
Successfully negotiated a bi-lateral APA between Japan and the UK for a global semiconductor production group.
Advised a global business on supply chain optimisation and the creation of a single hub for IP, procurement and sales related activities.
Advising a big data technology company on a valuation for tax purposes an intangible asset involving sensitivity analyses to address a lack of comparable market data.
Advising a European Fashion House on transfer pricing and duty implications of expanding its sourcing activity in Asia to take control over additional aspects of the supply chain.
Advising a global medical devices group on a significant number of complex valuations to support a restructuring of its supply chain and legal entity structure.
Advising a household goods group on a strategic review of transfer pricing relating to procurement operations in Hong Kong and China, and advice on approach to settling a long-standing dispute.
Advising a LATAM beverage company with operations in over 30 countries on a large-scale supply chain project involving strategic changes to its operating model, IP planning and setting-up an own-brand business under a more efficient structure.
Advising a number of Japanese parented groups to manage and defend their transfer pricing arrangements and rethink their business models.
Advising A US Headquartered Retailer on its expansion into Europe, including the establishment of a European principal company and the migration of IP from the US to Europe and performing an IP valuation.
Advising an industrial equipment business on due diligence for the potential acquisition of numerous businesses in Asia.
Advising BIA Foods on integrating various acquisitions for our global client as they expanded their business into the coffee sector.
Advising Columbia Threadneedle on a review of the effectiveness and sustainability of the Luxembourg feeder structure from a UK and Luxembourg tax perspective, including commenting on applicability of Luxembourg transfer pricing rules.
Advising Convatec on a significant number of complex valuations to support a restructuring of its supply chain and legal entity structure.
Advising Hitachi on compliance including provision of ongoing ad hoc transfer pricing support to Hitachi Europe Limited (EMEA’s HQ), including the performance of benchmarking searches as maybe required.
Advising large digital economy business on settling a diverted profits tax investigation on favorable terms
Advising PIMCO on the settlement of three tax assessment deeds issued by the Tax Authorities following a tax audit performed by the Tax Police and focused on the TP compliance of intragroup transactions.
Advising TESCA on TP documentation for the group, with innovative fee structure for brokerage agreement; fee scale depending on profitability of the business generated by the head office for the subsidiaries; and audit defense in Slovakia.
Advising TripAdvisor Ltd on a tax audit procedure started on possible existence of a deemed permanent establishment in Italy and determination of the amount of income to be allocated on such permanent establishment.
Advising Vodafone Group on providing expert reports in transfer pricing litigation in New Zealand regarding application of the arm’s length principle to credit rating analysis and loan pricing.
Advising Worldwide business on supply chain optimization and the creation of a single hub to house IP, procurement and sales related activities for a business spanning multiple jurisdictions worldwide and over a hundred entities.
Conducted a critical review of a tax authority's profit-split model to support MAP negotiations, and helped develop alternative parameters for calculations.
Performed and documented a detailed value chain and functional analysis plus profit-split calculations to support a client's negotiations with a tax authority prelitigation.
Advised a UK-based multinational on historic thin capitalization, and modeled impact of new interest deductibility rules.
Designed and implemented a new brand licensing structure for a FTSE-100 company across its operations worldwide.
Awards and recognitions
"Their grasp of commercial realities, the structures we have and our commercial drivers is very strong."
Chambers UK
2017
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05 January 2021