Global TP Policy & Documentation Centralisation
Client: European-headquartered SaaS group with 66+ entities.
Challenge: The group faced fragmented documentation, inconsistent narratives across jurisdictions, and limited local capacity, creating audit exposure and inefficiencies.
Our Approach: We established a centralised TP and documentation framework aligned with BEPS Action 13, creating a coherent global structure that supported scalability and improved control.
Impact: Harmonised TP documentation across all entities, reduced compliance costs by ~50%, and improved long-term reporting consistency and governance.
Intercompany Loan Pricing & Policy Structuring
Client: European holding company with multiple financing arrangements.
Challenge: Lack of clear loan pricing and contemporaneous support created significant audit exposure.
Our Approach: We delivered an intercompany financing benchmarking aligned with OECD principles and reflective of the group’s credit and commercial profile.
Impact: Strengthened the defensibility of intercompany financing and mitigated potential TP adjustments.
Post-M&A TP Integration & Capability Building
Client: US-acquired European manufacturing group.
Challenge: Post-acquisition integration challenges arose from a fragmented TP model and limited visibility into legacy structures.
Our Approach We aligned the TP framework with the group’s new operating model and delivered defensible transition documentation connecting legacy and redesigned structures.
Impact: Established a unified TP model, improved internal capability, and enabled smoother post-deal integration.
Global Withholding Tax (WHT) Compliance & Sales Enablement
Client: Swiss-headquartered software reseller operating in 180+ countries.
Challenge: The group experienced inconsistent WHT outcomes and lacked a unified mechanism to guide commercial teams on tax-sensitive pricing decisions.
Our Approach We created a globally consistent WHT framework that enabled informed commercial decisions and strengthened overall tax governance.
Impact: Reduced global tax leakage and enhanced the accuracy and speed of cross-border pricing decisions.
TP Model Redesign for Business Expansion
Client: Lithuanian entity of a European technology group.
Challenge: The group’s expanding product and service portfolio rendered its existing TP model outdated and misaligned with its evolving structure.
Our Approach We designed an updated, economically sound TP framework aligned with the revised business model and the group’s evolving commercial strategy.
Impact: Delivered a TP model that supported the expanded value chain and established a sustainable basis for ongoing group restructuring.
TP Adjustment Defence for Construction Group
Client: Malaysian construction group with Indian operations.
Challenge: A substantial TP adjustment of INR 25 crores created significant financial and reputational risk.
Our Approach We developed a robust TP defence strategy clearly aligning the pricing model with the group’s functional and economic profile.
Impact: The adjustment was fully withdrawn, and the matter was resolved in the client’s favour.
Multi-Country TP Compliance for Construction Group
Client: Canadian construction group with operations in the UK, Malaysia, and Singapore.
Challenge: The client required first-time TP compliance across multiple jurisdictions with decentralised data and varied process maturity.
Our Approach We established a cohesive multi-country TP compliance framework aligned with jurisdictional requirements and the group’s operational structure.
Impact: Achieved full compliance in all jurisdictions and enabled a consistent annual documentation cycle.
Capacity Building for a National Tax Authority
Client: Bangladesh National Board of Revenue under an EU-funded programme.
Challenge: The authority sought to strengthen its TP audit and benchmarking capability and adopt globally aligned approaches within practical resource constraints.
Our Approach We delivered a structured TP and international tax training curriculum aligned with global guidance and focused on practical audit application.
Impact: Enhanced institutional capability, with 50+ officers trained and a more structured TP audit and benchmarking methodology adopted.
Intercompany Cost Reallocation & Tax Efficiency Strategy
Client: Global technology group with a Global Delivery Centre.
Challenge: Misaligned allocation methods and inconsistent tax treatment led to significant leakage and inefficiencies.
Our Approach We established a defensible and tax-efficient cost allocation model aligned with operational substance and cross-border tax requirements.
Impact: Achieved CHF 460K+ in annual tax savings and established a scalable allocation framework supporting long-term efficiency.
DEMPE Analysis & Trademark Fee Structuring
Client: Multinational group undergoing internal IP restructuring.
Challenge: The group required an arm’s length framework for internal trademark transfers and licensing arrangements.
Our Approach We designed a DEMPE-aligned trademark and licensing framework supported by sound economic and governance principles.
Impact: Enabled compliant internal IP transfers, improved fee structuring, and strengthened long-term IP governance.