Transfer pricing is not an exact science: it requires value judgements by both the administration and taxpayers.
Given that the OECD itself openly acknowledges the complexity of this matter, our work as consultants is to give our clients the necessary legal certainty to carry out their transactions within the established legal framework.
Our participation in this kind of project begins with an understanding of the corporate and operational structure of the group of people and companies affected. Then, we analyse the consistency of the operations carried out taking for reference those existing in the market between independent parties, which meet the arm's length principle.
In recent years, we have been putting together documentation supporting the related transactions (Master Files and Local Files), both in the regional and common territory and abroad, relying on our international network (Globalaw) to comply with applicable regulations in other countries.
Our clients trust us, from the planning of their transfer pricing policy to its defence in the checks carried out by the Inspectorate of Taxes.
To carry out this work, our teams of economists, tax advisors and commercial lawyers assess the related transactions, analyse their fiscal implications (both nationally and internationally) and develop appropriate agreements or contracts.