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IFA 2011 Congress highlight | Transfer Pricing


A strategic approach for global business performance

Multinational Enterprises (MNEs) have to adapt to rapidly changing commercial and economic environments:

  • There is an increasing focus on compliance, enforcement and legislative approaches, and dealing with these complex issues is a significant challenge
  • With local and global regulations becoming more prescriptive, the number and complexity of tax investigations being conducted by specialised teams within local tax authorities is rapidly escalating, and the quantum of tax adjustments is rising accordingly.

Within this framework, the design and implementation of internal pricing now represents much more than a compliance issue. Clear and practical advice is critical to the establishment of a robust, tax effective structure; transfer pricing is providing significant opportunities for MNEs to adapt internal remuneration policies to maximise tax effectiveness and ensure close alignment with business and commercial strategies.

A full range of services

Our tax lawyers have extensive experience of dealing with tax authorities in many countries on transfer pricing cases and of successfully bringing such cases to a positive conclusion. This practical experience together with in-depth know-how in economics enables CMS firms to provide defensible, strategic advice. This expertise [link to CMS_TransferPricing-2011.pdf] covers the full scope of transfer pricing issues, from the most advanced planning to the downstream management of tax audits, through global or local documentation, and integration of transfer pricing policies with other tax and legal issues. This includes:

  • Local and global transfer pricing documentation
  • Financial and economic studies
  • Transfer pricing policies for intellectual property
  • Tax audits and litigation
  • Advance pricing agreements
  • Double taxation cases

An integrated tax and economic approach

CMS firms have developed an integrated transfer pricing practice with its own economics resource. This team is able to provide you a full range of economic analysis from the most standard comparables searches to more complex studies such as activity-based costing, applications of the game theory, business or asset (including intellectual property) valuation.

As this Europe-based economics team has managed and coordinated the work of recognised local experts in North and South America and Asia, our practitioners are able to deliver truly global advice:

  • They are a coordinated international team
  • They have a proven track record and a prestigious client base


Bruno Gibert – CMS Transfer Pricing Group coordinator
T +33 1 47 38 43 78
E [email protected]


If your organisation has to deal with national and international tax issues on a daily basis, against an increasingly complex legal background, contact us. To help you to tackle these complexities, our organisation has over 350 lawyers who offer comprehensive tax planning and advice services across Europe. We also have tax specialists Africa (more specifically in Maghreb), the Americas and Asia.

For specific requests concerning Transfer Pricing matters, do not hesitate to contact Bruno Gibert, our CMS Transfer Pricing Group coordinator or your usual CMS contact should you wish to discuss any new challenges your business is facing.

Intangibles, a key source of growth
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Bruno Gibert
Bruno Gibert