EXPERTISE
Our clients value our objectivity and our years of hands-on practical experience working with tax authorities, enabling us to provide insights that help further companies’ long-term objectives. We assist our clients in such areas as:
✓ Litigation support including economic analysis, expert reports and trial testimony
✓ Transfer pricing investigations by tax authorities and supranational organizations
✓ Advance pricing agreements and Competent Authority negotiations
✓ Global transfer pricing policy formation and implementation
✓ Controlled pricing versus market-based pricing
✓ Intellectual property, royalty rates and cost sharing
✓ DEMPE functions, value and profit uplift
✓ Economic evaluation of intercompany contracts
✓ Transfer pricing risk assessment and mitigation
✓ Illegal state aid allegations concerning transfer pricing
✓ Reconciliation of:
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U.S. section 482 regulations
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OECD Guidelines given “BEPS”
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European Commission approaches to transfer pricing
AREAS OF EXPERTISE
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