Transfer Pricing Restructuring

Our Firm advices throughout the entire restructuring process, this is, from the initial preparations until the effective process has finalized, with the following objectives:

• Assure and justify the rationality in the restructuring operation (“TP business purpose test”)
• Identify the transfer of tangible and intangible assets, and valuate them
• Establish and value the need of an economic compensations towards the related entity affected by the restructuring process
• Assure the correct alignment of functions-risks-profitability-taxation regarding the post-restructuring process
• Built the documentary compliance of the restructuring focusing on justifying and validating it from a Transfer Pricing perspective

We also perform the TP Due Diligence of the entities involved in M&A transactions.

Transfer Pricing will work in coordination with the manager, consultants, accountants and lawyers of the company.