Practice

Transfer Pricing

In today's environment, transfer pricing needs to be done effectively. It needs proper analysis and clear communication.

Representative experience

Performed and documented a detailed value chain and functional analysis plus profit-split calculations to support a client's negotiations with a tax authority prelitigation.

Advised a UK-based multinational on historic thin capitalization, and modeled impact of new interest deductibility rules.

Designed and implemented a new brand licensing structure for a FTSE-100 company across its operations worldwide.

Advised a global business on supply chain optimisation and the creation of a single hub for IP, procurement and sales related activities.

Conducted a critical review of a tax authority's profit-split model to support MAP negotiations, and helped develop alternative parameters for calculations.

Drafted expert opinions on a number of cases involving allegations of value-shifting through non-arm's length transfer pricing.

Events

DPT / TP and dispute resolution breakfast seminar: Spring 2018

The Hogan Lovells tax and transfer pricing team are delighted to invite you to their 2018 breakfast seminar on DPT/TP and dispute resolution, again with guest speaker Mark Carnduff from...

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Events

TP/Disputes Breakfast Seminar

The Hogan Lovells DPT / TP and dispute resolution seminar, with guest speaker Mark Carnduff from HMRC, will be taking place on Wednesday 28 June. Mark has recently moved from Business...

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Hogan Lovells Publications

Transfer pricing and mergers and acquisitions in Africa

As a result of competitive pressures, the current global economic conditions and advancements in technology, multinational enterprises (MNE) are often forced to adapt their business by...

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Hogan Lovells Publications

Transfer pricing documentation – Soon to be compulsory?

Currently, South African law does not explicitly require taxpayers to be in possession of transfer pricing documentation. Legislation does, however, place an onus on the taxpayer to prove...

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