Transfer pricing
Svalner Atlas offers transfer pricing models adapted to the individual business and tax optimised to undertakings in multinational groups. At present, there are a number of transfer pricing development projects underway in the OECD and EU, and tax agencies in various countries are expending significant resources to audit cross-border transfers of profit within multinational groups. Pricing cross-border intra-group transactions and documenting them with quality is a major challenge, and significant tax risks can arise if they are not handled or documented correctly.
A multinational group’s need for support with transfer pricing questions depends on its business and requires an in-depth understanding of the relevant industry as well as the relevant transactions – which is why we always maintain close cooperation with our clients.
Our services include
- Designing of efficient transfer pricing models
- Supply chain efficiency
- Cost saving initiatives, including adaptions for VAT and customs considerations
- IP management
- Risk mitigation
- Finance and treasury
- Loan models and credit facilities
- Debt mapping and cash management
- Financial guarantees
- Treasury companies
- Cash pools
- FX risk management
- Transfer pricing controversy
- Support in transfer pricing audits
- Litigation
- Mutual Agreement Procedures (MAP)
- TP documentation / compliance
- Masterfile
- Local files
- Country-by-country reporting (CbCR), including Public CbCR readiness
- Benchmarks
- Intra-group agreements
- Other
- Attribution of profits to permanent establishments (PEs)
- Advance pricing agreements (APA)
Contact
Related news
Svalner Atlas Group is joining forces with Fiscales, a well-known Finnish boutique firm providing high-quality tax advice and comprehensive financial management services.
