Pro-TP Implementation of appropriate transfer pricing 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.

Therapy of tranfer pricing structures

What should be done?


1 – Fixing transfer pricing mistakes for past years (as far as still possible) by

  • Implementing intercompany pricing where required
  • Revisiting the form and content of intercompany agreements
  • Identifying gaps in existing documentation and taking appropriate steps to fill same.


2 – Implement an appropriate transfer pricing system by

  • Determining the most suitable transfer pricing methods for intra-group transactions
  • Providing suitable intra-group agreements for intra-group transactions
  • Providing the required (minimum) additional transfer pricing documentation according to the rules of the countries in which the group operates. Requirements differ by country as follows:
    •   short memos describing the business structure and transfer pricing methods applied (plus necessary intra-group agreements), where nothing else is needed
    •   ‘local files’ for companies of the group in cases where documentation for some companies of the group is mandatory (plus necessary intra-group agreements),
    •   ‘master files’ giving information on the structure of the group, its business and intra-group transactions as well as ‘local files’ for companies of the group in cases where such
      documentation is mandatory (plus necessary intra-group-agreements),
    •   ‘country-by-country-reporting’ where necessary.
  • arranging for benchmarking studies’ (by experienced and competitive suppliers) demonstrating the adequateness of the group’s transfer prices by third-party-comparisons


3 – Keeping the transfer pricing system up-to-date in the future by

  • Adjusting pricing, agreements, and documentation in light of changes in the business and structure of the group
  • Adjusting pricing, agreements, and documentation as a consequence of changes in legal requirements


How will it be done?

  • As much as necessary to comply with the rules (to avoid unpleasant discussions with auditors, taxmen, higher taxes and fines)
  • As little as necessary (to avoid unnecessary internal rules, procedures, documents, and data as far as possible)



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