Professional Transfer Pricing / Pro-tp – the Service
Professional transfer pricing / Pro-tp is a tax compliance and consultancy service to international businesses in the field of transfer pricing.
Pro-tp Knowledge and Team
Pro-tp comprises an independent network of tax consultancy and law firms in Ireland, the Netherlands, and Germany. Our transfer pricing services leverage on these firms’ shared knowledge and experience. Transfer pricing support in other jurisdictions is provided by independent firms located all over the world. Wherever and whenever needed, these independent firms will assist in local transfer pricing matters.
Pro-tp members have provided clients with tailor-made transfer pricing solutions in more than 25 countries for more than 50 years and are able to assist clients who have operations in a large number of countries. It distinguishes itself from other international TP groups transfer pricing consultants because it has independently selected who its qualified partners should be.
Together, our experts offer more than 25 years of experience in developing transfer pricing strategies and documenting same for clients running cross-border business worldwide.
Pro-tp Structure and Philosophy
Pro-tp’s structure allows it to be flexible and Pro-tp as an independent network can work with multinational businesses and their advisors without having to deal with and manage conflicts of interest. This makes Pro-tp a unique service in the market. It also enables our team to react quickly to the needs of clients. As Pro-tp is specialized in crossborder-intra-group-transactions, its expertise allows it to identify transfer pricing issues quickly and implement solutions in a more cost-effective manner.
The philosophy of Pro-tp is to provide TP solutions tailored to clients individual needs, by using tested tools to structure and document transfer pricing systems. A specific solution will be developed for each unique case. Our expertise gained over the years allows us to share our knowledge and provide high-quality service. We adhere to the fundamental rule “Keep it clean, keep it simple, keep it flexible!”. This philosophy is not only incorporated into the solutions we develop for our clients, but is also reflected in our internal processes and organizations.
Pro-tp Common Tools and Standards
Pro-tp has set up a common database and a shared toolkit which is constantly updated to provide transfer pricing services in an efficient and timely manner. Pro-tp members work on the basis of a common service standards for the development, improvement, and implementation of transfer pricing structures to attain better, faster and less costly results.
Pro-tp Services to Independent Accountants and Tax Advisors
We offer our Professional Transfer Pricing services also to independent accountants and tax advisors who do not have special expertise or capacities in transfer pricing. Pro-tp will work with the client’s advisor just on transfer pricing issues. The client’s advisor will continue to manage the client relationship.
The Transfer Pricing Problem
- The continuous development of transfer pricing regulations coupled with the increased volume and diversity of intercompany transactions has made transfer pricing a high-risk area for MNCs that must be managed carefully. Transfer pricing regulations encompass a plethora of business activities from investment and intellectual property to the sale and purchase of goods and services and intragroup lending.
- Businesses with one foreign branch or subsidiary, as well as large-scale multinationals all have to document their international intra-group-business according to increasingly complex standards.
- Stricter laws and regulations make transfer pricing a tricky business and TP issues are increasing an area of focus during tax audits. When tax authorities decide that inter-company transfer pricing structures or documentation does not comply with the TP rules, they are likely to levy increased taxes and fines, often in two or more countries at once. The quality of a group’s transfer pricing structures and its documentation are an increasing area of focus during tax audits.
The Professional Transfer Pricing (pro-tp) Solution
Our Pro-tp-specialists offer transfer pricing solutions by rendering the following services:
Transfer pricing reviews, encompassing functional, risk and benchmarking analysis. Pro-tp will review the current cross-border intragroup transactions to verify whether or not they comply with the tax rules of the affected countries.
- Due diligence
Pro-tp will undertake a due diligence review of the historic and current business in order to detect past and present TP deficiencies. This review will form the basis of the provision of practical and flexible solutions.
- Implementation of appropriate strategy
We will assist in reorganizing and restructuring intercompany transactions according to acknowledged and legally accepted international transfer pricing rules. We will provide our clients with suitable intra-group agreements, transfer pricing documentation (including a master file and local files) prepared in accordance with local requirements and appropriate benchmarking studies to include third-party-comparisons for intercompany pricing. All these services can be provided at very competitive rates.
- Tax audit and litigation support including dispute resolution
In the event of challenges from tax authorities or other third parties, we can provide the requisite technical expertise to support the transfer pricing position taken by a group.