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Transfer Pricing & Intercompany Arrangements

Pricing Positions Built to Match Where the Substance Actually Sits

Averites advises multinational groups, investors and related businesses on transfer pricing and the legal arrangements governing transactions among affiliated entities.

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OUR APPROACH

How We Advise on Transfer Pricing and Intercompany Arrangements

  1. Why Transfer Pricing Is Central to International Tax Positions

    Transfer pricing is increasingly central to the tax position of international corporate groups. Tax authorities examine not only the price assigned to an intercompany transaction, but also whether the allocation of income corresponds to the functions performed, assets used and risks actually assumed by the relevant entities.

  2. Arrangements We Advise On

    We advise on transfer pricing frameworks for management and support services, distribution and supply arrangements, intellectual property licensing, development services, cost-sharing and cost-allocation arrangements, intercompany financing and other related-party transactions.

  3. Working With Economic and Tax Advisers

    Our lawyers work with economic and tax advisers on functional and risk analysis, pricing methodologies, benchmarking and documentation and ensure that the underlying contracts correspond to the economic substance of the arrangement.

  4. Why Legal Documentation Matters as Much as the Pricing Analysis

    Legal documentation is particularly important. An agreement that allocates significant risk or ownership to an entity that does not have the personnel, authority or assets required to perform the relevant function may create exposure even if the written pricing analysis appears technically defensible.

  5. Transfer Pricing as Part of the Broader Corporate Structure

    We therefore approach transfer pricing as part of the broader corporate and operational structure of the group rather than as a standalone compliance exercise.

  6. Reviewing and Reorganizing Existing Arrangements

    Averites also assists businesses reviewing or reorganizing existing intercompany arrangements following acquisitions, international expansion, changes in management, relocation of personnel or movement of intellectual property.

  7. Responding When Transfer Pricing Positions Are Challenged

    Where transfer pricing positions are challenged, we advise on responses to tax authority inquiries, audits, assessments and disputes and work with economists, accountants and other experts where appropriate.

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Precision across borders. Book a Meeting

New York c/o Chornous Law PLLC
30 Wall Street, 8 Floor
New York, NY 10005 Phone: +1 650 382 7764
London 124 City Road
London, England
EC1V 2NX Phone: +44 7405 138109
Kyiv 11 Panasa Myrnoho Street
Office 1/1
Kyiv, 01011 Phone: +380 63 148 27 37

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FAQ

Frequently Asked Questions

  • Transfer pricing is increasingly central to the tax position of international corporate groups. Tax authorities examine not only the price assigned to an intercompany transaction, but also whether the allocation of income corresponds to the functions performed, assets used and risks actually assumed by the relevant entities.

    • We advise on transfer pricing frameworks for management and support services, distribution and supply arrangements, intellectual property licensing, development services, cost-sharing and cost-allocation arrangements, intercompany financing and other related-party transactions.

      • Both. Our lawyers work with economic and tax advisers on functional and risk analysis, pricing methodologies, benchmarking and documentation and ensure that the underlying contracts correspond to the economic substance of the arrangement.

        • Yes. An agreement that allocates significant risk or ownership to an entity that does not have the personnel, authority or assets required to perform the relevant function may create exposure even if the written pricing analysis appears technically defensible — legal documentation matters as much as the economic analysis.

          • No. We approach transfer pricing as part of the broader corporate and operational structure of the group rather than as a standalone compliance exercise.

            • Both. We assist businesses reviewing or reorganizing existing intercompany arrangements following acquisitions, international expansion, changes in management, relocation of personnel or movement of intellectual property.

              • We advise on responses to tax authority inquiries, audits, assessments and disputes and work with economists, accountants and other experts where appropriate.