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.

Preparation of Master files, Local files, CbCR
and Local forms with respect to the pricing
of all types of international related party
transactions, in accordance with the OECD
guidelines and the local tax requirements.

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.

Conduct of prudential reviews of transfer
pricing systems, utilizing our in-depth
knowledge and experience of the practical
approach taken by tax authorities to
advise clients of their key transfer pricing
exposures, and the impact on the
calculationof tax contingencies for
accounting disclosure purposes;

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;

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.