Transfer pricing

 

 

 

Transfer pricing

To regulate transactions made by multinational and national groups, transparency and compliance rules have been established, such as the Principle of Fair Competition, also known as market value or “Arm’s Length”, which unfulfillment may imply facing important fiscal risks.

 

We have built up a multidisciplinary team of professionals with high academic preparation, technical knowledge, and analytical capacity, which we put at your service and allow us to perform in-depth analyses with different approaches of intercompany operations, to provide comprehensive and reliable advice that will support you in anticipating the resolution of problems that may arise in the future, and to advise you with a high degree of reliability in the matter.

We have a cutting-edge technological infrastructure that provides specialized software, calculation models, international databases with information from public and private companies from 180 countries and internal technological developments.

    Our solutions on transfer pricing

    • Documentation at the national, regional, and global level before an environment of Base Erosion and Profit Shifting (BEPS)
    • Assitance in preparing, reviewing, and filing informative returns of related party transactions of article 76-A of the Income Tax Law (Annex 9, local file, master file and country-by-country report)
    • Studies of documentation and planning in the subject matter
    • Diagnostic analysis in the subject matter
    • Analysis, planning, and determination of transfer pricing policies
    • Operations optimization analysis in supply chains and risk structure
    • Assistance in the resolution of disputes and negotiations with the tax authorities
    • Transfer pricing documentation in accordance with the regulations established in the license contract’s and the Hydrocarbons Revenue Law
    • Advisory and preparation of resolution requests of Advance Pricing Agreements (APA)
    • Optimization of the structure of functions, assets, and risks through the application of economic models (value chain analysis and intangibles valuation)
    • Valuation of intangible assets (brands and patents)
    • Valuation of machinery, equipment, and real estate
    • Valuation of financial assets

    Lead Partner

    Agustín Espino

    Transfer Pricing Lead Partner