Design and optimise transfer pricing models aligned with your business and value drivers. We help implement practical, defensible structures that balance tax efficiency, substance, and operational simplicity.
TP Structure Design
A transfer pricing structure defines how intercompany transactions operate across your group. Companies need a TP structure when entering new markets, scaling operations, revising their value chain, raising funding, or ensuring that their business model aligns with regulatory expectations. A strong structure provides clarity, compliance, and a sustainable foundation for growth.
What we do:
- Analyse your value chain and commercial model to design scalable intercompany frameworks.
- Define transaction flows, functional roles, allocation keys, and pricing logic aligned with substance.
- Minimise tax leakage across WHT, VAT/GST, customs, and corporate taxes while ensuring operational practicality.
Our experience:
- Designing TP structures for SaaS platforms, software companies, fintech and health-tech startups, digital marketplaces, online retailers, and multinational service providers.
- Designing scalable TP models for multinational groups across Europe, Asia, the US, and emerging markets, tailored to diverse industry and regulatory landscapes.
TP Implementation & Execution
TP implementation converts your approved TP structure into day-to-day business practice. Companies need implementation support when rolling out new TP models, integrating acquisitions, introducing new intercompany arrangements, or ensuring consistency across accounting, finance, and operations.
What we do:
- Prepare implementation roadmaps with timelines, responsibilities, and workflow integration.
- Embed TP policies into finance, accounting, invoicing, ERP, and operational processes.
- Provide ongoing advisory during business changes, monthly/quarterly reviews, and transaction-level execution.
- Assist during group reorganisations, M&A integrations, and entity-level restructuring.
Our Experience:
- Implementing TP models in both in-house and advisory roles across digital, SaaS, fintech, health-tech, retail, manufacturing, and logistics groups.
- Supporting execution of service fees, IP licensing models, procurement flows, distribution arrangements, TP true-ups, forecasting, accruals, and invoicing.