Creatrust provides you with a global perspective based on our long-standing experience of what really works in transfer pricing and tax-effective supply chain management.
Transfer pricing is a term used to describe all aspects of intra-group pricing arrangements, including transfers of intellectual property or the use of intellectual property, tangible property, services, loans and other financing transactions. As multinational groups seek to increase their level of operational integration, complex intra-group transactions across borders have grown rapidly. At the same time, tax authorities in the countries involved are increasingly challenging transfer pricing arrangements and tend to impose stricter penalties, new documentation requirements, increased information exchange and greater audit / inspection activity. Awareness and compliance are, therefore, essential.
Applying a correct transfer pricing policy may, however, not only allow a multinational group to reduce potential tax risks, but it may also create tax opportunities.
Creatrust can advise clients on their financial restructuring and can assist them in complying with the transfer pricing documentation requirements set forth in the related Circulars. The following list is an example of Creatrust's areas of expertise:
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the tax implication of transfer pricing transactions
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methods of comparability
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pricing of the transactions
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the preparation of transaction valuations
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the incorporation of company, holding or intellectual property rights management
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double tax treaties and permanent establishment in Luxembourg
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VAT aspects on transfer pricing transactions
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functions and risk analysis
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preparation of the documentation required by the tax authorities
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