SECTORS

As start-ups grow and expand operations internationally, transfer pricing considerations become increasingly important.

START UPS

PLANNING FOR CROSS-BORDER OPERATIONS

• Should I set up a subsidiary in a particular country?

• What are the tax implications of having employees working remotely in different countries?

• How do I fund a new subsidiary?

• How do I transfer sales revenue collected in a sales (or regulated) entity to a company that hires employees?

• How to price goods and services between group entities?

• Should we be paying tax in one company when the whole group is lossmaking?

• What transfer pricing, tax considerations and regulations should we keep in mind when expanding our operations internationally?

• The auditors / banks / regulators are asking for a transfer pricing documentation. Is there a robust but cost-efficient alternative?

AFTER A FUNDING ROUND

YOUR INVESTMENTS IN INTELLECTUAL PROPERTY AND CUSTOMER BASE GROWTH

• How can we transfer funds between our entities in different countries?

• Should we fund the entities by capital contribution or by related party loan?

• What interest rate should we use?

• What intangibles does my business have (brand, software, knowhow, product)?

• Which entity should pay for the investments into these intangibles?

• How can we license our valuable intellectual property to our affiliates at a market royalty rate?

• What factors should we consider when transferring IP between group entities for strategic or risk management purposes?

These questions are simple? Check our Scale-up section for more.

If intragroup arrangements are not managed correctly from the beginning, this can lead to penalties and unnecessary tax leakage. If you’re a start-up, you may be facing questions our clients usually ask, we can support in solving those questions in a practical and efficient way.

SCALE UPS

A global transfer pricing model can help centralize your efforts, create efficiencies and facilitate your strategic goals.

TRANSFER PRICING POLICY AND DOCUMENTATION

• What is our group tax strategy?

• Are our transfer pricing policies consistently applied across all entities?

• How can we ensure that the transfer pricing policies have been followed correctly by the accounting team?

• We have a successful fintech business – how do we create a commercial and compliant transfer pricing structure within the constraints of the international taxation?

• How to simplify / automate the monthly invoicing of the intercompany transactions?

• We are spending a lot of money and time on creating transfer pricing documentation in each country. How to make our Master file and Local file documentation process more efficient without losing the local touch?

• How to automate our transfer pricing documentation process? Should we licence a transfer pricing solution?

• How to create a well performing tax function?

FINANCING TRANSACTION

YOUR INTELLECTUAL PROPERTY OWNERSHIP

• How can we ensure that our intercompany loans comply with the tax and transfer pricing regulations?

• What is our intragroup financing policy?

• How should we consolidate the working capital in the group entities into a cash pool?

• How do we price intragroup financing transactions to comply with the tax regulations in a cost-efficient way?

• We are fintech in various jurisdictions – should we be having this input VAT leakage?

• Is there a co-ownership of valuable intangibles across several jurisdictions?

• Should we centralise our IP?

• Are we utilising tax incentives for innovation in the jurisdictions we operate in?

• How can we ensure that our intercompany licensing agreements comply with transfer pricing regulations?

• What factors should we consider when valuing our IP for transfer pricing purposes?

THE OPPORTUNITIES OF MERGERS AND ACQUISITIONS

• What tax and transfer pricing considerations should we keep in mind when integrating newly acquired entities into the group and our transfer pricing model?

• Should we charge something from / to our newly acquired business?

• How to integrate the new entities into the existing transfer pricing structure?

• Should we leave the intangible property in the acquired company? What are the tax and transfer pricing regulations we should consider?

• How to value the IP, customer base and other intangibles we want to transfer from the newly acquired business?

THE EXIT IS APPROACHING

• Have we optimized our corporate tax position?

• Are we running material transfer pricing and international tax risks?

• What steps can we take to ensure that our transfer pricing policies and documentation are up-to-date and accurate?

• What are the key tax and transfer pricing issues that we should be aware of when considering different exit strategies?

• What tax and transfer pricing considerations should we keep in mind as we prepare for an IPO or sale?

We provide solutions to many more questions for our scale up clients in varied sectors including, amongst others, marketplaces, fintech, ecommerce, SaaS, healthtech.

PERMANENT ESTABLISHMENT ISSUES

• How can we ensure that our employees working remotely across different jurisdictions do not create a material permanent establishment risk for our company?

• How can we determine the threshold for permanent establishment in each country we operate in?

• Are we running material permanent establishment risks? How to monitor those?

• How can we ensure that we are complying with tax and transfer pricing regulations when engaging independent contractors or third-party service providers in different countries?

If intragroup arrangements are not managed correctly from the beginning, this can lead to penalties and unnecessary tax leakage. If you’re a start-up, you may be facing questions our clients usually ask, we can support in solving those questions in a practical and efficient way.

The below is a small sample of questions we help our scaleup client to resolve.

CORPORATES

We bring innovation to conventional transfer pricing documentation and consulting.

We also work on retainer arrangements to expand the day to day capabilities of your inhouse tax or transfer pricing function.

END-TO-END TRANSFER PRICING SERVICES TO CORPORATE CLIENTS

• CbCr

• Master file

• Local file(s)

• Selection of automation and TP solutions

• Selection of automation and TP solutions

• Design

• Implementation, including operational transfer pricing

• Documentation:

FUNDS AND ASSET MANAGEMENT FIRMS

We partner with asset management, private equity and venture capital firms helping them maximise portfolio value.

• Inter-group and intra-fund financing policies

• Excel models for pricing financial transactions

• Support in structuring intragroup financial transactions, including intermediary financing structures (UK, Luxembourg, Cyprus and others) and pricing of derivatives

• Transfer pricing documentation for funds in various asset classes

• M&A transfer pricing support: due diligence, structuring and acquisition financing

• Valuations of intangibles and shares

• PE portfolio companies’ review to identify value chain optimisation opportunities

• IPO readiness support

• holding structure substance review

• other ad-hoc transfer pricing advice

WE CAN SUPPORT AM FIRMS AND FUNDS IN VARIOUS WAYS