Contact our Transfer Pricing expert

Jimmie
Jimmie van der Zwaan

Partner

Phone

+31 6 12 74 42 43

Email

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Transfer Pricing: Practical advice that works

As CFO or Tax Director of an internationally operating organization, you know that transfer pricing compliance is becoming increasingly complex. Borgen Tax offers you the assurance of correct transfer pricing and the required documentation that complies with local requirements and legislation.

Our practical approach and hands-on guidance from experienced transfer pricing specialists ensures that you remain compliant while continuing to operate your business.

Discover our services

Strengthen your tax position globally with reliable transfer pricing expertise

What is Transfer Pricing and why is it crucial?

Transfer pricing involves setting prices for transactions between related companies within a group. These transfer prices must be arm's length, as if they had been agreed upon between independent parties (arm's length principle). For companies operating internationally, correct transfer pricing is essential to:

  • Ensure compliance in all jurisdictions in which you operate
  • Avoid double taxation between countries
  • Minimize tax risks during tax audits
  • Optimize business processes within tax frameworks

Documentation requirements vary by country and are increasingly strictly enforced. Without adequate substantiation, you run the risk of time-intensive and costly disputes with tax authorities.

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Expertise with proprietary tools for maximum efficiency

Self-built tools for fast, flexible Local Files and Master Files with sound technical foundations.

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Short lines, partner-led guidance

Compact teams guided by experienced partners for efficient communication, quick decisions and cost control.

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International network, local expertise

Through our Taxand network, direct access to specialists in 50+ countries for consistent, coordinated transfer pricing approaches.

Our Transfer Pricing services in detail

Local File and Master File

Efficiently prepare mandatory transfer pricing documentation with our proprietary tools. We ensure your documentation meets local requirements in all relevant jurisdictions.

Annual updates and monitoring

Continuous monitoring of your transfer pricing position with timely updates of documentation and methodologies. We identify developments that impact your compliance.

Benchmark Studies

Based on a selection of comparable companies from specialized databases to substantiate the arm's length principle of your transfer pricing.

Transfer pricing model development

Design of robust transfer pricing models in international expansion, acquisitions or business reorganizations. We translate your business strategy into a fiscally sustainable model.

Intercompany agreements

Drafting legal agreements that capture your transfer pricing model and are consistent with your documentation and benchmarks.

Business restructuring guidance

Tax support for international restructurings, IP transfers and centralization of functions. We ensure that changes are implemented correctly.

APA procedures

Guidance on obtaining Advance Pricing Agreements for prior assurance of your transfer pricing methodologies.

Mutual Agreement Procedures.

Support in cross-border disputes to avoid double taxation.

Tax Authorities

Professional representation and communication with tax authorities for audits and information requests.

Local File Tool

Our in-house developed application for fast and flexible setup of Local Files with AI support for report generation.

Debt Capacity Analysis Tool

Advanced analysis for substantiation of intercompany financing and creditworthiness of group companies.

Master File Generator

Automated generation of Master Files with consistent quality and extensive customization capabilities.

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Analysis and strategic model development

We analyze your business model and organizational structure to develop robust transfer pricing models that translate your business strategy into fiscally sustainable solutions.

Thorough business model analysis

Customized strategic models

Robust tax structures

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Implementation and documentation with proprietary tools

Our proprietary developed tools ensure maximum efficiency and quality in the preparation of Local Files and Master Files with room for customization and solid substantiation.

In-house developed TP tools

Efficient Local/Master Files

Consistent intercompany agreements

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Compliance monitoring and proactive guidance

We provide annual updates, monitor compliance in all jurisdictions and guide APA proceedings for prior assurance.

Annual updates and monitoring

Multi-jurisdictional compliance

APA guidance and dispute support

Multi-Currency Cash Pooling & Transfer Pricing Compliance.

Discover how we helped a multinational enterprise optimize group-wide liquidity through a physical multi-region cash pool. Expert guidance on arm's length substantiation, benchmarking, legal implementation, policy design, and stakeholder alignment to ensure OECD-compliant transfer pricing and sustainable liquidity management.

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Transfer Pricing

Frequently Asked Questions

All companies entering into transactions with related parties (group companies) must have documentation to substantiate the pricing for these transactions. The documentation required depends, among other things, on the size of the consolidated turnover and whether the transactions are cross-border. For companies with consolidated group sales in excess of €50 million, more extensive documentation requirements apply. (Master File and Local File)

Annually, incorporating significant changes in your business model, acquisitions or changes in local regulations.

Tax authorities can request your documentation and review methodologies. Good documentation shifts the burden of proof to the tax authorities. Currently, there is a lot of focus on the selection process when conducting a benchmark and the two-sided approach.

Safe harbors and simplified methods exist for certain standard transactions (e.g., "low value adding services"). We advise on the best approach for your situation.

With our tools, we can prepare Local Files within 2-4 weeks, depending on the complexity of your organization.

Schedule a meeting with our experts

Do you have questions about transfer pricing?

Book an appointment directly via the calendar, or reach out to us by phone or email. Our specialists are ready to help you.

Phone

+31 6 12 74 42 43

Email

jimmie.vanderzwaan@borgentax.nl