Transfer Pricing

A global view on a business-critical, fast-evolving issue

Organisations that span international borders are increasingly facing complex regulatory and tax issues in the different jurisdictions where they operate. Transfer pricing is at the top of the tax priority list for many mid-sized and large businesses, with an outsized impact on and business units. We offer a range of solutions for transfer pricing management so you can ensure compliance with local regulations.

Our approach

There is greater scrutiny of transfer pricing the world over. Only a global, multi-layer approach can bring simplicity to this fast-evolving issue. Our global partnership in more than 90 countries provides the vital expertise in tracking developments such as new legislation and court/tribunal rulings in each jurisdiction, through direct contact with our transfer pricing experts who have deep industry know-how and the local and international expertise necessary. 

Our International Transfer Pricing Community brings together specialists from across disciplines, including economists to help with value chain analysis: a vital tool to align transfer pricing with economic value creation and establish transfer prices for intangibles. Data is the foundation for a robust transfer pricing regime. Recognising this, we have created databases and tools such as a cloud-based system to ease reporting under the EU’s DAC6 directive.

Our service begins with a diagnostic risk assessment that seeks to highlight areas for savings, as well as exposure. We then work closely with you to make sure you can meet your documentation obligations and optimise your tax positions.

Our services

  • Strategic advice on all aspects of transfer pricing
  • Master file, local file and country by country reporting
  • Tax audits, mutual agreement procedures
  • Value chain analysis and transformation
  • Economic analyses, including commercial benchmarks, loan benchmarks, and license benchmarks
  • Cash pools and other integrated group wide financing systems
  • Transfer of functions, valuation of transfer packages, exit taxation
  • Valuation of hard to value intangibles

Our tools & solutions 

With Transfer Pricing Genie, we offer a digital transfer pricing documentation solution that is a more efficient approach to increase transfer pricing processes. We also offer database access, including Bloomberg and RoyaltyStat, as well as the automatic transmission of country by country reports (CbCR) and data exchange through our Signals tool.

Our people 

Our team consists of experienced tax specialists and transfer pricing experts with country and sector specific tax and industry knowhow, accountants and economists, which ensures that we can provide, develop and implement customised transfer pricing solutions that fit with our clients’ commercial and tax strategies.

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Documents

Mazars_​OECD_​Guidance .pdf
Mazars BEPS and International Tax News n1_​February 2021.pdf
Insights into the FTA practical guidelines on intragroup interests_​March 2021.pdf

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