Here are descriptions of a few of the engagements that we have worked
- 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
- 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
- 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.