Transfer pricing applies to corporate groups with a multinational dimension. Within these groups, all transactions must be conducted at market rates and specific documentation and reporting requirements can apply.
Our experts assist you in determining market-compliant conditions, whether or not through benchmarking analysis, and implementing an internal transfer pricing policy. Our area of expertise also includes the preparation of mandatory transfer pricing documentation.
What is transfer pricing and why is it important?
Transfer pricing implies that all transactions between related companies must be on arm’s length terms. Thus, the prices charged to a group company must be similar to the prices an independent party would pay in similar circumstances.
All intra-group transactions must follow this general principle, both when providing goods or services and when paying interest to a group company. If a tax audit reveals that the prices or conditions charged are not in line with market conditions, corrections may be imposed, possibly resulting in double economic taxation. In practice, obtaining relief for this is often a long and difficult process.
Large companies are also subject to an obligation to prepare transfer pricing documentation, which consists of a Master File and a Local File. Corporate groups with consolidated group revenue of at least €750 million must also file a Country-by-Country Report.
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