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.

International Tax Dispute Resolution & Litigation Summit

Senior Director of Economics & Transfer Pricing, Graham Poole, will be speaking at the International Tax Dispute Resolution & Litigation Summit, on the subject of Diverted Profits...

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Published Works

Tax disputes in 2017

Diverted profits tax disputes will come into real focus this year. For many early cases, much of the one year ‘review period’ where negotiation and agreement are expected will...

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