Transfer Pricing Services
We’ve categorized our Transfer Pricing services in 8 categories.
Learn more about these 8 categories and their underlying services, or check out all our Transfer Pricing services.
Transfer Pricing services categories
Transfer Pricing Software
Within the transfer pricing and tax landscape there are many software solutions. The right choice depends on your business model, systems, and compliance needs. As an independent transfer pricing firm, Quantera Global advises which software vendors may best serve your situation. We help you decide what fits best Our role is to clarify needs, compare options, and help you […]
Transfer pricing benchmarking
The transfer pricing benchmark analysis is used to set and test your transfer pricing policy. Quantera Global assists your company in setting up a well-documented transfer pricing policy, by performing a full-fledged analysis, or help you update the current policy. The policy we set up will contain an at arm’s length remuneration, to prevent disputes with tax authorities.
Rulings
Rulings are formal agreements with tax authorities that provide upfront certainty on how tax law and transfer pricing apply to your specific facts, using instruments such as APAs (bilateral or multilateral), Innovation Box rulings and MAPs to reduce audit risk, prevent corrections and mitigate double taxation.
Governance, design & strategy
Governance, design & strategy is the setup of your transfer pricing framework, aligning policies with your business model, defining roles, controls and oversight, and advising on restructurings, intangibles and APAs to reduce risk and create value, with implementation support and metrics.
Controversy
Controversy is the management of all interactions with tax authorities around transfer pricing, from proactive audit preparation and communication to handling audits, risk reviews, expert opinions and resolving disputes through MAP or arbitration to reduce risk and eliminate double taxation.
Financial Transactions
Financial Transactions is the practice of setting and pricing intragroup loans, guarantees, cash pools and other treasury arrangements, and documenting them to meet the arm’s length standard, with credit analysis, benchmarking and clear policy documentation.
Compliance
Compliance is the preparation, maintenance and filing of transfer pricing documentation and disclosures, including Master File, Local Files, CbCR and intercompany agreements, aligning evidence with your policy to meet local rules and reduce audit risk.
Operational transfer pricing
Operational Transfer Pricing is the practical execution of your transfer pricing policy, pricing individual intercompany transactions, booking them correctly in ERP and financial statements, and monitoring results so outcomes align with policy.
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Quantera Global, pleased to meet you!
Quantera Global is the largest independent transfer pricing boutique firm. We have a personal approach, global coverage and support our clients in the full circle of transfer pricing.
Our passion is to support our clients with solutions and to enable them to manage their transfer pricing challenges. To offer the best support it is essential to know and understand their needs.
As Abraham Lincoln once said: “If I only had an hour to chop down a tree, I would spend the first 45 minutes sharpening my axe”.
This may be a bit exaggerated, but this is how we prefer to do things at Quantera Global. We spend time with our clients to understand their business, underlying questions, and tax implications. This enables us to develop optimum transfer pricing solutions with and for our clients.
This translates into our typical 4-step approach:
Pre-analysis
Collection and review of information
Analysis
Determine optimum approach/scenario
Realization
Deliver optimum solution
Next steps
Further support
All Transfer Pricing services
Transfer Pricing Software
Within the transfer pricing and tax landscape there are many software solutions. The right choice depends on your business model, systems, and compliance needs. As an independent transfer pricing firm, Quantera Global advises which software vendors may best serve your situation. We help you decide what fits best Our role is to clarify needs, compare options, and help you […]
Transfer pricing benchmarking
The transfer pricing benchmark analysis is used to set and test your transfer pricing policy. Quantera Global assists your company in setting up a well-documented transfer pricing policy, by performing a full-fledged analysis, or help you update the current policy. The policy we set up will contain an at arm’s length remuneration, to prevent disputes with tax authorities.
Rulings
Rulings are formal agreements with tax authorities that provide upfront certainty on how tax law and transfer pricing apply to your specific facts, using instruments such as APAs (bilateral or multilateral), Innovation Box rulings and MAPs to reduce audit risk, prevent corrections and mitigate double taxation.
Governance, design & strategy
Governance, design & strategy is the setup of your transfer pricing framework, aligning policies with your business model, defining roles, controls and oversight, and advising on restructurings, intangibles and APAs to reduce risk and create value, with implementation support and metrics.
Controversy
Controversy is the management of all interactions with tax authorities around transfer pricing, from proactive audit preparation and communication to handling audits, risk reviews, expert opinions and resolving disputes through MAP or arbitration to reduce risk and eliminate double taxation.
Financial Transactions
Financial Transactions is the practice of setting and pricing intragroup loans, guarantees, cash pools and other treasury arrangements, and documenting them to meet the arm’s length standard, with credit analysis, benchmarking and clear policy documentation.
Compliance
Compliance is the preparation, maintenance and filing of transfer pricing documentation and disclosures, including Master File, Local Files, CbCR and intercompany agreements, aligning evidence with your policy to meet local rules and reduce audit risk.
Operational transfer pricing
Operational Transfer Pricing is the practical execution of your transfer pricing policy, pricing individual intercompany transactions, booking them correctly in ERP and financial statements, and monitoring results so outcomes align with policy.
Mutual agreement procedures (MAPs)
Mutual agreement procedures (MAPs) can be used by taxpayers if they end up in a situation of double taxation due to a transfer pricing correction made by a tax authority. Simply put, the taxpayer requests the competent authorities of the jurisdictions involved to discuss with each other what the arm’s length pricing should have been in order to eliminate double taxation. The MAP is regulated in the OECD Model Tax Convention, tax treaties and the EU Arbitration Convention.
Advance Pricing Agreements (APAs)
Advance Pricing Agreements (APAs) are legally binding agreements between the taxpayer(s) and the tax authorities that are used to obtain prior clarity on the application of transfer pricing methods and/or transfer pricing rules for a particular set of transactions. This Transfer Pricing agreement could include an agreement on the appropriate transfer pricing methodology for a particular (set of) transaction(s). An APA is a specific form of a tax ruling. APAs must be aligned with the law and the transfer pricing regulations of the applicable countries.
Bilateral and Multilateral APAs (BAPAs and MAPAs)
Advance Pricing Agreements (APAs) are legally binding agreements between the taxpayer(s) and the tax authorities used to obtain prior certainty on the application of transfer pricing methods and/or transfer pricing rules for a certain (set of) transaction(s). This Transfer Pricing agreement could include an agreement on the most appropriate transfer pricing method to be applied. APAs must be aligned with the law and the transfer pricing regulations of the countries involved.
Innovationbox
The Dutch innovationbox regime is a preferential tax regime to stimulate R&D activities in the Netherlands. The main benefit of the Dutch innovationbox is that profits generated with innovative activities are subject to a reduced effective corporate income tax rate in the Netherlands.
Transfer Pricing Strategy
A good transfer pricing strategy is essential for any MNE. When your company is considering a new strategy, QG can provide support in this process. We can help to mitigate risks and seize opportunities.
Governance
Good governance is the process and system by which an organisation is controlled and operates. Different elements that are part of good governance are ethics, compliance, administration and risk management. QG offers board support, a transfer pricing control framework and awareness sessions.
Pillar Two Support
As part of the OECD BEPS-Project, the OECD has introduced the Two-Pillar Solution as a way of updating key elements of the International Tax System, as the current tax systems are unable to cope with the globalised and digitised economy.
Sparring partner
Sparring partner Many of our clients are experiencing various developments in their business. They like to have a sparring partner who understands their business and its position and who can provide pragmatic advice in a quick and efficient way by addressing only the needs of the company. We enjoy being a sparring partner and are […]
Transfer pricing analysis
All transactions between related entities should be at arm’s length. This is a very important principle in international tax law. A transfer pricing analysis is required to determine the arm’s length price. The tp analysis will show whether there are opportunities and possible threats within the current transfer pricing policy.
Strategic sessions
In the strategic session, our experts gain a deep understanding of the composition and structure of your company, even in the most complex situations. Our team is specialised in understanding your business. The strategic session can focus on a specific topic you would like to focus on or your overall transfer pricing policy.
Support in local transfer pricing audits
A transfer pricing audit is an investigation by a tax authority to ascertain whether a company is compliant with transfer pricing regulations. Tax authorities conduct such audits to ensure that their taxpayers are compliant and report sufficient profit.
Risk reviews
Your company may have doubts about how to deal with controversy. Do you need a proactive controversy strategy or will a retroactive approach suffice, you might wonder.
Arbitration and mediation
With the help of the Mutual Agreement Procedure (MAP), tax administrations resolve an increasing amount of (international) tax treaty disputes. However, there are still many dispute cases that remain unresolved.
Expert witness testimony / opinion
As an independent transfer pricing firm, we are in the perfect position to provide an expert witness testimony / opinion on legal procedures concerning transfer pricing.
Cash pooling
Cash pooling is a method often used by multinational companies for cash management and intra-group financing. QG sets up proper transfer pricing documentation in combination with a robust transfer pricing policy for your cash pool activities.
Intercompany funding
Forms of intercompany funding are cash pools, notional pooling and intercompany loans. With the help and support of Quantera Global, your company will have a well-documented and clear intercompany funding policy.
Financial guarantees
A financial guarantee is a guarantee provided by one entity on behalf of another entity against a third party-liability. The service QG offers is design and analysis of the financial guarantee, including the determination of the economic benefit derived from the guarantee, the effect of group membership and risk exposure of the guarantor.
Captive insurance
Captive insurance may be relevant for large multinationals and refers to an entity whose insurance business is to provide (and/or to support with) insurance policies for the multinational group. The main advantage of this structure is to reduce fees to external insurance companies and to create synergy benefits.
Transfer Pricing Implementation
The services QG offers include the implementation and documentation of transfer pricing policies as well as financial transactions. Monitoring the correct transactions is also part of our service.
Intercompany loans
Intercompany loans are loans from one entity to another, within the same company. This can offer your company multiple advantages, such as quickly shifting cash between entities or avoiding bank fees. QG can help to prepare all relevant documentation for intercompany loans.
Transfer pricing local file
Local files are an important part of the required transfer pricing documentation. Quantera Global can help your company set up solid documentation, such as local files. If your company is faced with (additional) documentation requirements, our advisors can support you.
Transfer pricing master file
The master file focuses on describing the context in which intercompany transactions take place. The transfer pricing master file is prepared at group level. Quantera Global can take care of all your transfer pricing documentation including preparation of the master file. We can review whether your current documentation meets all guidelines and requirements.
TP documentation for SMEs and start-ups
Small and Medium Enterprises and start-ups often do not have to meet the master file and local file requirements but can prepare documentation in a free format. QG can support with a policy that meets the lower documentation requirements and provide internal and external clarity on the application of the transfer pricing policy.
Intercompany agreements
An intercompany agreement (ICA) is a signed contract between two or more associated entities. Quantera Global can assist your company in drafting these agreements. And we ensure that all these important aspects are included in the agreement.
Transfer Pricing Compliance Overview Service
Transfer pricing compliance is about meeting all regulations issued by tax authorities. To make sure your company is compliant QG offers a transfer pricing compliance overview service. This solution will help your company to make informed decisions with respect to your transfer pricing compliance and never miss deadlines.
Transaction reports
Transactions can be described either in local files or prepared as such a separate transaction report for consistency and efficiency. The transaction report covers specific or one-off transactions. Quantera Global is an expert in preparing transfer pricing documentation, such as transaction reports.
Country by country reporting
The country-by-country report is an important document for meeting transfer pricing documentation requirements. It is an annual requirement, including the related annual notifications. QG can help your company set up all required transfer pricing documentation, such as the CbCr.
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