Approximately two-thirds of cross-border transactions take place between associated enterprises part of the same multinational group, keeping the pricing of intercompany transactions at arm’ s length is an unavoidable need for multinationals as well as medium-sized enterprises. Pressure from international and regional organizations as well as local tax administrations require full compliance with the arm’s length principle. The importance of such element is reflected in the circumstance that increasingly MNE (Multinational Enterprises) groups rank transfer pricing as one of the highest risks to be managed, from a reputational as well as from a tax standpoint. Thanks to our significant expertise in both design of transfer pricing policies as well as assistance in litigation proceeding, we are constantly able to tackle the most challenging issues associated with the commercial and financial relations existing in transactions between associated enterprises. We have at our disposal access to the commercial and financial databases needed to perform a thorough comparability analysis to determine the most accurate economic results consistent with application of domestic transfer pricing provisions.
What do we offer?
Transfer Pricing Compliance: TP Documentation
In a post-BEPS (Base Erosion and Profit Shifting) world, where tax administrations around the world are implementing the recommendations focused on transfer pricing (with a specific focus on Action 13 related to TP documentation and CbC reporting) Ecovis’ transfer pricing professionals assist taxpayers with home country and foreign documentation requirements by preparing transfer pricing documentation reports that analyze the arm’s length nature of their intercompany transactions. This includes supply of goods, provision of services, as well as intercompany financial transactions. We can also assist multinationals with multiple foreign affiliates to prepare global documentation, including Country-by-Country reporting, meeting all of their documentation requirements in an effective manner.
Ecovis’ transfer pricing professionals assist clients with all aspects of defending their transfer prices before the tax authorities and with local audit teams before entering the confrontational environment of a transfer pricing audit. Our services relate to all the various phases of entering into an advance pricing agreement, with a focus on the pre-filing meetings, filing of the request and submission of the comparability study instrumental to enhance the transfer pricing model selected by our client. We provide assistance on APA on a multi-jurisdictional scale.
Dispute Resolution: Examination Defense and Mutual Agreement Procedures
Due to the increasing amount of transfer pricing disputes arising across every jurisdiction, it is very likely that instances of economic double taxation may occur. It is in this very moment that Ecovis professionals come into play and assist taxpayers in activating mutual agreement procedures (MAPs) based on tax treaties or – at the European level – on the arbitration convention to deal with competent authorities all around the world.
Business Model and Supply Chain Optimization
In light of today’s dynamic global economic environment and the potential for legislative changes, assessing a multinational’s global business model may no longer be an optional exercise. The Ecovis team of transfer pricing professionals provides high quality, customized tax and business model transformation Services. Ecovis works with clients to explore strategic opportunities to enhance global tax and treasury planning, by aligning the relationship between the taxpayer’s value drivers and income/cost streams to improve their effective tax rate (ETF). This can include supply chain and intellectual property strategies and global charges. Ecovis transfer pricing services help integrate operational and tax decisions in a way that allows clients to treat tax as another cost of doing business making strategic decisions on an after tax Basis.