Our services cover all aspects of the advisory and compliance TP business lifecycle:
Planning & Design
Whether long-standing international structures exist or the group is new to international business, there can be TP design needs. We have extensive practical experience in design and implementation of TP policies and operating models, arising from material factual, market or economic change. All transaction types including intellectual property, tangible goods, services and financing are in scope.
Regulatory changes can alter the landscape, giving rise to changing operating models. OECD activity around the BEPS initiative could, for example, mean that there is a desire to move away from stripped risk distribution or commissionaire structures and replace them with more traditional full risk buy/sell distribution models.
Groups need to be confident that their structures are robust and generate results which satisfy the arm’s length principle, whether under OECD, US §482 or UN guidance.
Changes in operating models require practical, hands on, operational support. In our experience, a lack of operational TP support can let down the very best theoretical model. Real-time implementation and ongoing running of TP design adds incremental value.
We have the technical IT expertise to assist with model implementation, from data retrieval to the modelling of business transactions, enabling price setting, monitoring and adjustment, as necessary to satisfy the arm’s length standard.