Perhaps the most frequent concern about transfer pricing is compliance. Nowadays, taking into account the new norms suggested by the OECD in Action 13  of its BEPS plan, is necessary to develop a coherent, integrated and accurate approach to demonstrate the arm’s length value of the intercompany transactions across the entire organiza tion. Additionally, Our firm can assist you in bilateral or multilateral APA negotiations. For the maquiladora industry we can help you  to evaluate the safe harbor options provided by the Mexican Tax Authorities.

(Alignment of transfer pricing outcomes)

An adequate transfer pricing system starts considering the analysis of the business. Reasons behind each intercompany transaction, and its legal, accounting, tax and transfer pricing treatment. Our firm can assist you in evaluating such scenarios and choosing the best option considering your needs.

Optimizing intercompany transactions through the use of mathematical models and Big Data. Today most multinationals first minimize costs by varying production and logistic parameters and only then align transfer prices. Such approach does not guarantee the true operational and financial optimum. We have developed innovative solutions using mathematical models, new computer algorithms, and Big Data tools that will allow you to find the true maximum profit  after taxation. Our new approach streamlines the engagement process, reducing costs and increasing  efficiency, resulting in better and cleaner deliverables.

The OECD Action Plan on Base Erosion and Profit Shifting brings a new era for multinational companies. The expected changes to the global tax framework are of such a magnitude that they will affect  the OECD Model Tax Convention, the network of international treaties on double taxation, and the current Transfer Pricing Guidelines. A thorough review of  the current transfer pricing and international tax policies is necessary for multinational groups to anticipate the effects of the Plan and adjust their operations  accordingly.

Important issues arise every day related to the administration of any transfer pricing scheme. How to organize intercompany transactions? What are the tax implications of the operation, both domestically and internationally? What transfer pricing risks does the current business model hide? How to allocate the expenses derived from service provisions? How to organize a centralized treasury model? These are examples of frequent questions that are solved by our firm in a precise and expeditious manner.

Nowadays transfer pricing and international tax disputes are frequent. Our legal practice brings together attorneys at law well trained in transfer pricing,  international tax, and even domestic taxation issues with the objective to assist you in any tax controversy, prepare your intercompany agreements or negotiate your intercompany transactions.

Correct interpretation of income tax treaties is  essential to gain tax advantages. Issues like royalty or interest payments, identification of tax havens, use of favored national clauses, or issues triggered from the existence of a permanent establishment, are some aspects routinely addressed by our practice. We also can assist in evaluating tax implications of M&A, sale of shares, deferred taxes, and HQ reporting.

Our firm deals with experienced partners who can advise you on legal and customs matters, attend  to foreign trade processes, carry out customs tariff classification studies, devise models for operations, provide legal defense against customs and foreign trade matters, perform preventive audits, and also train your staff on topics of interest in this field.

We offer valuation services, following both the domestic and the international standards, to estimate the fair market value (FMV) for different assets, such as minority and/or majority shareholders’ interests,  intangible assets (trademarks, patents, software,  client list, etc.), and going concern privately-owned businesses.