Our transfer pricing services combine a unique blend of economics, tax and intellectual property (IP) law and expert dispute resolution skills with industry-specific commercial awareness.

Our focus is on high level strategic advice to provide the maximum value to our clients. Our Transfer Pricing Strategic Review process is a comprehensive review of three dimensions of transfer pricing:

  • Transfer pricing planning:
    • Improving the tax efficiency of supply chain restructuring and other business re-organisations including joint venture structuring and post-merger rationalisation
    • Financing and planning in the context of changed economic circumstances
    • Structuring of intangibles ownership, migration, development and licensing
    • Functional analysis and benchmarking to apply OECD guidelines to the attribution of profits to permanent establishments
    • Ensuring that 'quick wins' are identified and acted on
  • Transfer pricing dispute resolution:
    • Achieving greater certainty through advance pricing agreements, advance thin capitalisation agreements, rulings and informal tax authority agreements
    • Assistance with transfer pricing enquiries and investigations
    • Litigation support when necessary
    • Assisting with competent authority, mutual agreement process and European Arbitration Convention processes
  • Transfer pricing compliance:
    • Ensuring that immediate benchmarking and compliance obligations are met
    • Ensuring that transfer pricing risk management arrangements are adequate to maintain a 'low-risk' status in the longer term

Our international tax and disputes teams have an exceptional reputation and are consistently ranked as market leaders. Our international IP specialists advise on brands and products, patents and technology, and IP transactions, with special reference to the telecoms, media and technology sector and to pharmaceuticals, biotechnology and healthcare, frequently on a multi-jurisdictional basis. We combine all of these skills to act for local and international clients on domestic and cross-border transfer pricing issues including large-scale transfer pricing disputes.

Awards

European Tax Firm of the Year - International Tax Review European Awards (2011)

Tax firm of the Year (Germany and UK) - International Tax Review European Awards (2011)

View all awards

Brochures

Transfer pricing capability statement View

Transfer pricing and international tax disputes View

Briefings

Austria  View

The McKesson case: key transfer pricing principles in the context of debt factoring   View