Transfer pricing consulting and restructuring services

Transfer pricing is a very dynamic issue  both for companies and for tax administrations. Restructuring of the subsidiaries by their parent companies based on economic, financial and commercial parameters to ensure they are subject to different tax regimes in different countries, or centralisation of certain domestic services under holding structures for cost advantages requires regular review of companies' transfer pricing policies and revision of them, when necessary.

To this end, PwCTransfer Pricing Team, with its expert members, offers the following consulting services:

• review of intra-group transactions,
• review of agreements, procedures and terms related to these transactions,
• identification of the new transfer pricing method that should be applied, and
• determination of the transfer price (profit margin, royalty rate, interest rate, etc.) based on economic analysis and database search.

In the scope of transfer pricing policy changes or restructuring projects, studies are also carried out in coordination with PwC Customs and Indirect Tax, International Tax, People and Organisation Consulting, R&D, and Advisory teams, and accordingly, a common, multifaceted approach is developed.