Planning

Preparing for the future

Multinationals face heightened interest in their tax and transfer pricing positions. No longer just of interest to tax authorities, corporate tax positions have moved up the government and public agenda.

There is an old saying that the best defense is a good offense. In the transfer pricing world, the best way to safeguard against potential transfer pricing challenges is to set-up a proper transfer pricing policy in advance of commencing related party transactions.

The OECD recently published recommendations as part of its base erosion and profit shifting (BEPS) initiative that greatly expands the documentation burden on multinationals.

Together with other countries, Romania has already started the process of adjusting its transfer pricing legislation and compliance requirements to the new international trends. This makes aligning the TP policies and transactions in the light of BEPS measures crucial for the well-functioning of the tax and financing function with the multinationals.

We can help you with:

Assessing your existing transfer pricing policies, evaluate potential risks and advise on pragmatic corrective solutions, keeping in mind your global effective tax rate and tax management strategies.
Assisting you in designing and setting up a proper transfer pricing strategy and ensuring its stability by obtaining advance pricing agreements.
Helping prepare for the significant changes expected from the OECD activity on base erosion and profit shifting, including review of existing transfer pricing policies and inter-company agreements.
Assisting in complex transfer pricing planning including setting up of cost contribution arrangements, value chain transformation, as well as intellectual property planning.