SolutionsTransfer
Pricing

TPA Global approaches consulting from a multi-disciplinary perspective covering management control, economics, legal, tax, finance, and cost accounting. The flexibility of our business model enables us to provide transfer pricing services to our clients on a much more personal and hands-on basis wherever and whenever their businesses operate around the world. Our streamlined operating structure, coupled with our effective use of technology allows us to be cost-efficient while delivering superior quality advice.

Our professionals combine the technical skills of economics, tax, and business management to enhance your transfer pricing system, and help you effectively manage your transfer pricing risk. In addition, together with our global members, we provide guidance and hands-on assistance on the implementation of each key phase of a project with real insight and focus on the practical implementation issues arising from the introduction of your new transfer pricing system and business model.

The main transfer pricing services provided by TPA Global are: 

  • Design of transfer pricing systems – assistance to multinational clients in the design of global transfer pricing systems and pricing policies, to meet their commercial needs and to reduce the group’s transfer pricing risk;
  • Global/Regional (Masterfile) and country-specific transfer pricing documentation – preparation of documentation (with expert economic analysis and appropriate benchmarking) in respect of the pricing of all types of international related party transactions, in accordance with the OECD guidelines and the local tax requirements;
  • Advanced pricing arrangements (APAs) – preparation of all types of APA applications supported by expert financial and economic analyses, negotiation with the relevant tax authorities, and strategic management of the application process to ensure the best possible outcome;
  • Transfer pricing risk assessment and contingency evaluation – conduct of prudential reviews of transfer pricing systems, utilizing our in-depth knowledge and experience of the practical approach taken by tax authorities in order to advise clients of their key transfer pricing exposures, and the impact on the calculation of tax contingencies for accounting disclosure purposes;
  • Strategic audit defence – adopting a proactive and strategic approach to the conduct of transfer pricing reviews and/or audits, to minimize disruption to the day-to-day business of the company, and with the ultimate objective to reduce the risk and amount of transfer pricing adjustments, interest, and penalties by the relevant tax authority;
  • Transfer pricing and value chain planning – devising global and regional transfer pricing policies and value chain strategies, and assisting multinational clients with the implementation of those strategies, to manage their transfer pricing risks more effectively and/or to minimize as far as possible their overall tax rate.

BEPS / Global Tax Compliance

TPA Global promotes a global approach to tax compliance, which includes devising a strategy at group level and then implementing them at local levels using a sound corporate governance structure.

TPA Global works with a number of software providers to support multinationals in automating the annual preparation of Master files, local files and CbCR.

Tax Risk Assessment and Management / Alternative uses of Value Chain Analysis

Proactivity in managing your challenges is key in gaining full control. TPA Global offers a variety of services in the area of risk managament, which include:

Risk Assessment MeasuresDispute Avoidance Measures
  • Identification of key high-risk operations of the MNE;
  • Identification of key high-risk jurisdictions for the MNE’;
  • Identification of inconsistencies between tax, operating and governance models of the MNE arising our of the annual value chain analysis conducted for the TP documentation purposes;
  • Identification of applicable dispute avoidance instruments to the MNE.
  • Redesign of TP models, value chain analysis, other voluntary measures;
  • Unilateral, bilateral, multilateral APAs;
  • ISO certifications;
  • Co-operative compliance programs;
  • Safe harbour rules;
  • Pre-audit settlements.
What are you looking for?
Widen your skill set.
Stay connected.
On our Technology Suite.

Headquarters

H.J.E Wenckebachweg 210
1096 AS Amsterdam