As an organisation with global operations, you may be benefiting from strong growth in cross-border transactions. You are also subject to tighter regulations, complex multi-jurisdictional tax investigations, higher tax adjustments and an increasingly litigious approach to settling transfer pricing audits.
If you need advice on your transfer pricing approach, are negotiating with tax authorities or want advice on tax and commercial implications on implementation of transfer pricing policies, the multi-disciplinary CMS Transfer Pricing Team can assist.
We work across the European, Asian and American markets and have a proven track record in the financial services, retail, consumer, TMC and lifesciences sectors.
Global tax authorities are taking an increasingly bullish approach to the pricing of products, services and asset transfers within groups, and multinationals need to be fully aware of complex domestic and international transfer pricing regulations.
As new OECD and governmental initiatives take force, there is frequently a conflict in maintaining tax-efficient supply chain structures while not falling foul of complicated anti-avoidance legislation. A co-ordinated tax and legal approach to the pricing and documentation of internal cross-border transactions is critical, allowing multinationals to create water-tight commercial structures that minimise the significant risk of material tax adjustments at audit, while providing flexible pricing models that work in concert with global operational requirements.
With an extended network of dedicated teams across Europe, we offer a fully co-ordinated approach to ongoing transfer pricing and supply chain planning, while our deep technical and commercial expertise has allowed clients to reach valuable settlements at audit and litigation across numerous jurisdictions.