Settlement planning and structure

To ensure compliance with the arm’s length principle, transactions must be planned, structured and accounted for in a way which raises no doubts of the tax authorities in any of the countries in which the related parties are established. We assist our Clients in this respect by offering:

  • planning of the intra-group settlement structures and transfer pricing policies in observance of the transfer pricing safety,
  • assistance in drawing up the procedures of ongoing management of the transfer pricing risk,
  • advice on allocation of income of a permanent establishment,
  • reviewing settlements with related parties.