Value Chain Management, Transfer Pricing Documentation and Controversy and Dispute Resolution services cannot do without knowledge and experience in the areas of Financial Transactions and Tax Valuations. The sound, objective substantiation of Transfer Pricing is virtually a profession in itself.
Such substantiation demands knowledge of both taxation and financial economics. For this reason, aside from its tax specialists, experienced economists and financial specialists are also active in Meijburg & Co’s Global Transfer Pricing Services practice.
Demonstrability is key to Financial Transactions and Tax Valuations
The phrase ‘at arm’s length’ is used time and time again in the context of Transfer Pricing. Does your transfer pricing meet the conditions that an independent third party would have set? And for which intercompany transactions do you actually need to substantiate the transfer pricing? The intercompany transactions for which Transfer Pricing is regulated include the following four:
- Financing (loans, guarantees and cash pools)
- Intellectual property
We work on the basis of critical benchmarking
In the past, a benchmark study often sufficed for goods and service transactions. Nowadays, however, tax administrations are more critical, and set higher requirements in respect of search criteria and the keeping up-to-date of benchmark studies.
Higher requirements are also set in respect of financing and intellectual property transactions, now that tax administrations have an increasing amount of knowledge concerning the evaluation of these types of intercompany transactions. In our experience, the various tax administrations can adopt, in practice, quite different points of view on this subject.
We can implement benchmark studies for you cost-effectively. We also work in accordance with standard and reproducible protocols. These protocols are OECD-proof, and coordinated with the Dutch Tax and Customs Administration.
Complex tailored approach to financial-economic substantiation
Apart from benchmarking, Meijburg & Co also delivers complex tailor-made work. Our solutions include the following:
- Data mining in publicly accessible databases.
- Regression analyses.
- Loans and guarantee analyses.
- Royalty studies.
- Valuations of intellectual property, businesses and shares for tax purposes.
Want to know more about Financial Transactions and Tax Valuations?
If you would like more information about Financial Transactions and Tax Valuations, then Meijburg & Co would be pleased to discuss these with you. Please contact one of our Tax Valuation specialists.