Transfer Pricing

Our services

• Reviewing business activities / models relating to BEPS (OECD project concerning the reduction and transfer of profits) and assessing any risks
  
  
• Assessing possible differences between the contractual and operational company organisation, including:
  • value chain (risks, functions and assets)
  • processes
  • group transactions
  • transfer pricing methods
    
    
• Creating business models / group structures with a solid substance and implementing them (intellectual property rights and financing structures, value chain optimisation)
  
  
• Documentation
  • Preparing OECD-compliant local and master documentation
  • Defending transfer pricing documentation vis-à-vis the Swiss tax authorities in assessment procedures and during audits
  • Negotiating tax and transfer pricing agreements (Advanced Pricing Arrangements – APAs)
  • Coordinating transnational reporting projects (Country-by-Country-Reporting – CbCR)
    
    
• Determining, quantifying, administering and monitoring transfer prices and tax risks taking current BEPS developments into account