Functional analysis
Analysis of the role of the companies involved, the risks assumed, and the assets used.
Transfer Pricing
Expertise in transfer pricing between related companies. Analysis of arm's-length pricing and OECD methods.
When is this expert opinion required?
Expert opinions on transfer pricing involve assessing whether the financial terms applied between related companies comply with the arm's-length principle. They are required in particular to analyse royalty rates, intra-group interest rates, or as part of a tax audit or tax dispute.
METHODOLOGY
Our approach is based on OECD recommendations: functional analysis, the comparables method, and profit-split methods.
Implementation of OECD methods
Application of the comparables method and, where applicable, profit-split methods in accordance with OECD recommendations.
Determination of economic parameters
Estimation of royalty or interest rates based on market comparables or analytical approaches based on margins and the role of the assets.
Report and support
Recommendations for setting the rate or support in the event of a dispute with the tax authorities.
Trademarks, patents, know-how, and more broadly any asset or service transferred between companies within the same group.
OECD methods: comparables, profit split, and an analytical approach for royalties.
Yes. We assist our clients with audits and disputes with the tax authorities.
Based on market comparables or economic analyses that take into account the role of the asset and the margins generated.
WHAT WE OFFER
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Mastery of OECD frameworks
In-depth knowledge of OECD methods and recommendations.
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Economic expertise
Expertise in the valuation of intangible assets and international taxation.
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Enforceable reports
Documented deliverables for tax authorities and courts.
