Why this work
Transfer pricing trouble rarely starts with the form. It starts with a policy that does not match how goods, people or IP actually move. We map the transactions first, then the method, then the documentation.
APA conversations, Form 3CEB, local files and valuations sit in the same programme. If the operating model changed last year, the file has to say so. We would rather rewrite the policy than defend a story the plant cannot recognise.
Our offerings
What's included in our Transfer Pricing & Valuations service
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01
Intercompany policy
A method and a set of transactions that match how the business actually runs, written so operations can recognise it.
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02
Documentation and Form 3CEB
Local file, master file where needed, and the accountant report, kept to the same story as the ledgers.
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03
APA support
The application, the working papers and the meetings. We stay in the room after the filing, not only before it.
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04
Valuations for tax and IP
Income tax and licensing valuations with workings an officer can follow, not a black box multiple.
Frequently asked questions
Depends on the volume, the controversy risk and how stable the model is. We will say if an APA is worth the years, and if it is not.
Then the file has to change with it. We do not paper over a new warehouse or a new IP flow with last year’s method.
Yes. The number has to survive both a tax officer and a commercial conversation. We keep those two audiences in view.
Talk to us about transfer pricing
Bring the current policy and how goods or IP actually move. We will tell you if the file still matches.
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