• Elaboration of Transfer Pricing studies
• Analysis in perspective for implementation of new operations with related parties
• Analysis of corporate and operational profitability
• Advice on the completion and/or preparation of the annexes corresponding to Transfer Pricing in the ISSIF and tax annexes, as well as the informative declaration of transactions with related parties (Annex 9 of the DIM). See bulletin “Presentation of Annex 9 of the DIM”.
• Advice and preparation of related party informative declarations:
  • Master of related parties (Master fi le)
  • Local related parties (Local file)
  • Country by Country

• Advising on Transfer Pricing audits
• Advice on how to obtain unilateral APAs and /or
  bilateral
• Advice on group restructuring
• Valuation of shares
• Design the best structure with respect to functions and risks.
• Thin capitalization study
• Safe Harbor

Contact one of our specialists, who will be happy to advise you on the type of analysis that best suits your business needs.