TransferPricing
Policy, documentation and defence of intercompany transactions under the arm's-length principle. A defensible structure for every cross-border flow.
Transfer pricing rules require related-party transactions to be priced at arm's length, under the OECD and BEPS standard. T&C designs policy, prepares Local File and Master File, advises on APAs and defends intercompany transactions before tax authorities across Colombia, the UK, the UAE and other jurisdictions.
Intercompany pricing is decided once. You will defend it for years.
We design transfer pricing policies consistent with the group's economic reality and with OECD and BEPS standards. We document, defend and update every intercompany operation with a single objective: a structure that holds up to any audit without surprises.
Four fronts. One single standard.
Typical mandates.
Some recent examples
How we work.
Functional analysis
We understand the value chain, risks assumed and assets used before selecting a method.
Benchmarking
We build defensible comparables using international databases and real market insight.
Documentation
We produce local file, master file and CbCR aligned with OECD and local authorities.
Defence
We defend the policy through audits, appeals and international mutual-agreement procedures.
Functional analysis
We understand the value chain, risks assumed and assets used before selecting a method.
Benchmarking
We build defensible comparables using international databases and real market insight.
Documentation
We produce local file, master file and CbCR aligned with OECD and local authorities.
Defence
We defend the policy through audits, appeals and international mutual-agreement procedures.
Questions that arrive before the first mandate.
Bogotá. London. Dubai.
Every intercompany flow crosses at least two jurisdictions. We work in all of them, under one technical standard.
Arm's length,fully defensible.
An outdated policy surfaces during the audit, not before. Let's review it in time.