Awarded the 2018 Best Newcomer Firm of the Year in Europe by International Tax Review

Transfer Pricing

The increasing complexity of a company’s global footprint, coupled with the heightened scrutiny worldwide following the release of the Base Erosion and Profit Shifting (BEPS) Guidelines by the Organisation for Economic Co-operation and Development (OECD), transfer pricing has arguably become the most contentious area of international tax.

Transfer Pricing is commonly cast as both “art and science” yet that does not mean that the solutions need to be as confusing as the issue. Our aim is to “demystify” transfer pricing for our clients and empower them to do as much of the work as feasible with their in-house resources by leveraging the expertise of our seasoned advisors. We have a reputation in the industry for facilitating transformation from complex, perhaps outdated, structures into manageable, defendable transfer pricing systems that adapt to the dynamic demands of a global supply chain. We ground our analytics in the reality of your business; a stable transfer pricing system is found in the roots of your value chain.

In response to this increasingly complex tax environment, our clients have asked for an education offering that could be incorporated into the strategy of their tax department’s development and we aim to deliver. We are in the process of formulating a second dimension, intended to complement our consulting platform, with such educational resources that will empower clients through online training and implementation tools along with the option of customized workshops. Again, our aim is to demystify transfer pricing by empowering clients to the extent possible and to grow their knowledge base along with the complexity of the company’s transfer pricing system.

Controversy

Even the most solid transfer pricing structure will face inquiry by a tax authority at some point. We have walked in your shoes on audit and bring the experience to partner with you and prepare for an audit strategy through reviewing the contemporaneous information, filling in the gaps for what may exist, and unpacking the value chain story as it existed at the time of the transaction. Our expertise in understanding the interconnected nature of tax transformation and business strategy brings value to the discussion and gives you credibility at the negotiating table.

Planning and Strategy

In today’s tax environment, multinationals are focused on aligning their business and tax models. Best practice involves consideration of a "Plan B" in any strategy, particularly in international tax given the sweeping changes that are occurring in tax regimes around the world. It is critical that the tax structure reflects the economic reality of the business but maintains the flexibility for the business to maintain operational independence as a priority.

Implementation

We believe in the power of partnership and are committed to aligning with our clients’ needs, resources, and risk profile to bring value in the areas most relevant to them. Developing a transfer pricing policy is only one of many milestones in the best practices journey of a tax department.

We have created a unique team, comprised of former in-house transfer pricing professionals, complemented with the hands-on involvement of one of the industry’s leaders and most experienced transfer pricing professionals, having served clients in this highly-specialized area since 1993.

Aptis team members have sat in your chair as an in-house transfer pricing or tax professional and understand the challenges of increasingly complex business flows, aggressive tax authorities, burdensome compliance requirements and the inevitable mismatch between the issues and the resources to resolve them.

With our “Transition Champion” © approach, our former in-house champions are ready to come alongside an in-house transfer pricing professional to create a meaningful, implementable game plan with a call to action. This program is designed to leverage our education platform and tools to meet you where you are in the steep transfer pricing learning curve as you grow in your role as a value-added member of your tax team and your department's ‘go-to’ transfer pricing thought leader.

 

Compliance

Our team has seen transfer pricing documentation evolve from the beginning with the US Internal Revenue Code (IRC) 482 Temporary Regulations, promulgated in 1994. Our aim is to create a sustainable transfer pricing strategy, supported by solid, consistent documentation, to avoid potential controversy. We will partner with you to synthesize the complex facts of your business in the industry’s perspective most relevant to understanding the markets in which you operate, the intercompany relationships that surround the relevant transactions, and how those relationships impact the organization in narrating your value chain story. The new OECD model is intended to frame your company's value chain story through the key elements of value creation: Development, Enhancement, Maintenance, Protection, and Exploitation (“DEMPE”). This is your opportunity to position your company to maintain the value inherent in its tax structure.