Transfer pricing and financial services
Financial services groups face a perfect storm as tax authorities increase their transfer pricing reporting requirements and prudential regulators show a growing interest in pricing arrangements.
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 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 network in over 100 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 experts include specialists and economists for 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
We know that international companies are increasingly looking to prepare large amounts of their transfer pricing documentation centrally and consistently, so they can reach full coverage in an efficient way. That’s where our seamless approach comes in.
Reptune, an OECD compliant transfer pricing documentation software allows our global teams to easily monitor workflow management and ensure consistency wherever they are working from. Doing this means you get a service that is fast, efficient and accurate.
It follows a top-down approach where data management starts from the global perspective of the multinational before drilling down to a single group company and its individual transactions.
The software’s dashboard provides visual insight into transaction flows, documentation progress and financial performance, while the status page helps prioritise the work based on local deadlines.
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.
Get in touch with our transfer pricing team.
Pillar 2 GloBE
More than 140 jurisdictions have now signed up in principle to the global minimum tax framework, representing a ground-breaking plan to update key elements of the international tax system, which is no longer fit for purpose in a global and digitalised economy.
DAC6
The DAC6 Directive (EU) 2018/822 requires EU Member States to impose compulsory reporting obligations on intermediaries and taxpayers in relation to cross-border tax arrangements. Here you will find all the information you need about the regulatory framework, the challenges involved and our portfolio of DAC6 services
Transfer pricing and financing transactions
With the current economic landscape characterised by rising interest rates and volatile market conditions, businesses must be able to set arm's length prices for their financing transactions and manage interest deduction limitations effectively. This requires a thorough understanding of the relevant tax rules and regulations, as well as the ability to navigate complex financial transactions.
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Each month, find out about regulatory developments, particularly in relation to the introduction of the OECD's BEPS initiative, which could impact your tax obligations in the short or medium term.
Contact
Frédéric Barat Avocat Associé - Paris, France
