Groups operating internationally should should ensure that Transfer Pricing exposures are managed efficiently and that their policies can be supported if challenged. Otherwise they risk ultimately suffering in terms of management time and reputation as well as incuring additional tax liabilities and penalties.

In addition, a consistent Transfer Pricing policy can provide benefits such as:

• A lower effective tax rate;
• Relief for stranded losses;
• Better cost control; and
• Improved cash flow.

The client’s interests are always uppermost in our minds at Marccus Partners and Mazars when offering cost effective support. By using a structured approach, we are able to quickly discover the Transfer Pricing point of interest. For larger enterprises, we can set up a group documentation file using the EU-Master file, which oviates the need for separate initiatives at subsidiary level.

Our Transfer Pricing advice is both practical and value added as well as commercially relevant.