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Solutions Limited 2004-7
Representative engagements

Here are descriptions of a few of the engagements that we have worked on:
  • A project to integrate and rationalise the legacy transfer pricing systems in a merger of two companies in a services industry.  We replaced four transactions with a single royalty.  We considered withholding tax and deemed dividend consequences in twelve countries.

  • A comprehensive review of transfer pricing compliance in eleven countries, for an energy company.

  • A study to determine arm’s length debt:equity ratios for a consumer goods company.  Subsequent negotiation of advance thin capitalisation clearance with Inland Revenue for £1.4 billion of borrowings from US parent.

  • An extended (three year) Inland Revenue audit of an IT services business, defending the deductibility of £300m of royalties paid to the US parent for the brand name and various other intellectual property.

  • A transfer pricing project to redesign the supply chain of an entertainment company.  The solution involved designing a cost contribution arrangement to transfer to a licensing company the international rights in all intellectual property, plus conversion of other group companies to contract manufacturing and limited risk distribution.  Input from transfer pricing experts in six countries.

  • A study to design a transfer pricing policy for a B2C internet company.  The design was consistent with business needs, avoided potential VAT problems, reduced the anticipated effective tax rate of the group, yet was compliant with the arm's length test.  As it was expected the group would have start-up losses for the first three years, a further aim was to avoiding creating taxable profits anywhere in that period.

  • A project to design and document a defensible, yet simple, head office service fee methodology for an engineering products group with 45 group companies around the world.

  • A comprehensive review for an insurance company of all intra-group transactions, including reinsurance premiums, fund management fees, trustee and custodial services, loans, brand name, head office services.