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Transfer Pricing

Perfecting transactions for global operational success and compliance.

Transfer pricing refers to the pricing of transactions between related entities within multinational enterprises. It is a key aspect of international taxation, ensuring that profits are allocated appropriately across jurisdictions in accordance with the arm’s length principle. Adherence to transfer pricing regulations is essential to prevent tax disputes and avoid penalties.

Transfer Pricing

  1. Transfer pricing structuring

  2. Structuring activities such as business model optimization, business restructurings, and post-merger integrations, structuring of intercompany transactions etc.

  3. Operational transfer pricing

  4. Implementation of sustainable day to day management of transfer pricing operations, establishing processes for efficient utilization of data and resources.

  5. Value chain analysis

  6. Preparation of value chain analysis determining value drivers and associated functions.

  7. DEMPE analysis

  8. Identification of entities carrying out activities and assuming risks within development, enhancement, maintenance, protection, and exploitation in relation to a group’s intellectual property rights.

  9. Intercompany price setting

  10. Activities relating to price setting of intercompany sale and purchase of goods and services, including Intellectual Property Rights (IPR).

  11. Intercompany asset transfers

  12. Valuation and documentation related to cross-border intercompany asset transfers and business restructurings.

  13. Transfer pricing compliance

  14. Transfer pricing compliance including preparation of master files, local files, both for Danish and foreign entities, country-by-country reporting, and the mandatory controlled transactions forms.

  15. GAP analysis

  16. Transfer pricing documentation gap analysis, comparing Danish requirements with those of other jurisdictions to ensure compliance with Danish regulations.

  17. Intercompany agreements

  18. Preparation of intercompany agreements and agreement templates, including global agreement programmes, and implementation of intercompany agreements.

  19. Transfer pricing due diligence reports

  20. Preparation of buy-side and vendor-side due diligence reports for transfer pricing purposes.

  21. Cross-functional projects

  22. Cross-functional collaboration projects where transfer pricing should be taken into consideration, e.g., changes to the supply chain, setting up new entities, global mobility, etc.

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