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Transfer Pricing
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Transfer pricing is currently the biggest tax
issue facing multinational businesses.
Opportunities in a changing environmentToday, transfer pricing has become much more than a matter of compliance
for corporate taxpayers. It is currently the biggest tax issue facing multinational
businesses as tax authorities seek to establish and enforce new guidelines and
regulations.
With actions taken by the OECD, new regulations as well as more scrutiny from
the tax authorities, we are seeing an overall increase in inspection (both in rigor
and quantity) and a growing tendency towards litigation. Similar developments
take place within the EU, like state aid procedures. With this in mind you need
a team that is already one step ahead of the latest regulations and fine points
of law, is able to help you avoid litigation where possible (but ready to litigate
when necessary), and can guide you through the increasingly detailed and often
conflicting statutory transfer pricing codes in multiple jurisdictions.
At Loyens & Loeff, you can count on a multidisciplinary team of experts providing
strategic transfer pricing advice that turns issues into opportunities – an important
opportunity to simultaneously protect against double taxation, align inter-company
pricing with business strategy – and ultimately support corporate development.
Across markets and borders Loyens & Loeff
provides solutions on all relevant transfer
pricing issues.
Our servicesAcross markets and borders, Loyens & Loeff provides integrated solutions on
all relevant transfer pricing issues. Our major services include advice, dispute
resolution and documentation:
Planning & strategyWe analyse transfer pricing exposures and
opportunities and then advise on the best strategies,
blending our technical tax expertise with a thorough
understanding of the business, management
control, and knowledge of accounting systems that
our clients use. We advise amongst others on TP
policies, the set-up and conversion of business
models, restructurings, profit allocation to permanent
establishments and can assist clients in defining a
strategy on country-by-country reporting.
Dispute resolutionWe assist taxpayers with TP audits and resolve TP
disputes both at an administrative and court level.
Resolving international transfer pricing disputes
through mutual agreement procedures (MAPs),
using arbitration under tax treaties, or through the
EU Arbitration Convention, Loyens & Loeff is able
to work simultaneously across multiple jurisdictions.
Furthermore, our transfer pricing team has extensive
experience in successfully obtaining (bilateral)
Advance Pricing Agreements (APAs), which helps
limit complications in the event that additional
disputes arise.
DocumentationWe work hand-in-hand with you to produce tailor-
made transfer pricing documentation (whether local
or global) that reflects your aims, always keeping it
as compact and as cost-effective as possible. This
includes local files, master files, country-by-country
reporting as well as other documentation such as
intercompany agreements.
We integrate our transfer pricing expertise with
the various practices across our firm to offer
you a fully rounded response.
Our approachOur approach makes us stand out.
IntegratedAs transfer pricing is intertwined with many other tax and legal issues, we integrate
our transfer pricing expertise with the various practices across our firm to offer
you a fully rounded response. With tax experts in corporate income tax, value
added tax and customs duties, our team covers the full range of transfer pricing
issues ranging from legal analysis of transactions to dispute resolution. Often civil
law experts (for example Banking & Finance, Energy/Oil & Gas, Competition &
Regulatory, Corporate Law, Litigation & Risk Management) are also involved to
contribute and combine additional expertise and experience. Different from many
competitors is that we are able to integrate our tax advisers and lawyers in our
transfer pricing team, making it possible to provide an all-encompassing service
to our clients.
PragmaticAs we have everything in-house, we are able to keep costs down while delivering
the most integrated support possible, keeping our teams small and efficient and
providing advice with a highly pragmatic approach.
Due to the very nature of transfer pricing,
our home markets of the Benelux and
Switzerland position us perfectly when
offering advice on cross-border and pan-
European transactions.
Cross-borderDue to the very nature of transfer pricing, our home markets of the Netherlands,
Belgium, Luxembourg and Switzerland position us perfectly when offering advice
on cross-border and pan-European transactions. We have our own network of
offices in major financial centres and, through these offices, our clients have
access to Loyens & Loeff’s full-service tax and legal expertise in their own time
zone.
Equipped with attorneys-at-lawShould a dispute arise, our experts can represent clients in court. Clients also
benefit from the confidentiality of our legal advice thanks to the attorney-client
privilege attached thereto. At earlier phases in the process, the court experience
helps to create documentation and correspondence that could convince judges.
Contact
The Netherlands
Harmen van DamT +31 10 224 63 48
Rogier SterkT +31 20 578 53 09
Patrick van OppenT +31 20 578 51 33
Belgium
Natalie ReypensT +32 2 743 43 37
Luxembourg
Peter MoonsT +352 466 230 244
Switzerland
Beat BaumgartnerT +41 43 243 07 60
www.loyensloeff.com
Amsterdam
Arnhem
Brussels
Dubai
Hong Kong
London
Luxembourg
New York
Paris
Rotterdam
Singapore
Tokyo
Zurich
15-11-EN
-TRP
