TransFair Pricing Solutions (“TFPS”) provides independent transfer pricing advisory services in relation to financial, intellectual property, services and goods transactions across a wide variety of industries for multinationals, management companies, real estate & private equity funds and other investment vehicles.
Our services include the following :
Transfer Pricing Documentation
The transfer pricing documentation requirement applies to all types of intercompany transactions, meaning that all taxpayers subject to the arm’s length principle under income tax law need to document how the price is determined. No specific format is required by law for the documentation. We propose two options to document intercompany transactions:
Simplified transfer pricing analysis
Type of client: This option is recommended for associated enterprises performing no material intercompany transactions and willing to comply with transfer pricing requirements but that do not need a detailed documentation
Scope: It includes all the transfer pricing sections developed in a limited way to be in compliance with the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017 (the “OECD Transfer Pricing Guidelines”), the EU Code of Conduct on Transfer Pricing Documentation for Associated Enterprises in the European Union (“the “EU Code of Conduct”) and the Luxembourg Transfer Pricing Circular
Deliverable: This option includes a PowerPoint file and its appendices
Fees: It is fair and reasonably quoted
Integral transfer pricing documentation
Type of client: This option is recommended for associated enterprises performing material intercompany transactions and willing to comply with transfer pricing requirements as well as needing a detailed documentation
Scope: It includes all the transfer pricing sections developed in an integral way to be in compliance with the OECD Transfer Pricing Guidelines, the EU Code of Conduct and the Luxembourg Transfer Pricing Circular
Deliverable : This option includes a PDF file and its appendices.
Fees : It is fair and reasonably quoted
Transfer Pricing
policy analysis
An analysis to determine the mechanics to price transactions between related parties under certain terms and conditions
Transfer pricing
audit assistance
Support in developing strategies, technical approaches and discussions with the tax authorities to achieve a positive and sustainable outcome
Credit rating
analysis
An analysis to determine the credit worthiness of a company or of a particular obligation
Transfer pricing
design
Review of the business model in order to apply operating business model effectiveness approaches
Benchmarking
services
Benchmark analysis to determine an arm’s length compensation for the company. The benchmarking will be performed using relevant databases and adopting search criteria in line with the facts and circumstances of the company
Economic analysis
for rulings
Economic analysis to determine an arm’s length compensation for the company in line with ruling documentation requirements
Cost sharing
economic analysis
Transfer pricing analysis to determine whether the conditions established by related parties for transactions covered by a cost contribution arrangement are consistent with the arm’s length principle
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