DLA Piper

Maximizing value and minimizing risk in transfer pricing

With transfer pricing becoming increasingly important to tax authorities, companies are facing a range of complex economic and legal issues in supporting and managing tax positions. Our team of lawyers, accountants and economists know how tax authorities approach issues globally. We’ll guide you through the complexities to ensure you maximize value and mitigate risk.

Transfer pricing is an area where economics, business and law are intertwined. As your business continues to evolve, the proactive management of transfer pricing goes beyond compliance and can limit risk and uncertainty.

Our global Transfer Pricing team provides a range of transfer pricing and valuation services to help you plan, manage, document, and defend cross-border transactions.

Whether you’re a start-up or a multibillion-dollar corporation, we can design policies that balance your business needs and tax obligations. We’ll help you update and implement new operating models, policies and guidance, in line with business, economic and tax law changes. And we’ll ensure your transfer pricing documentation remains current with rapidly changing global compliance requirements.

“15 ranked jurisdictions International in Tax Review World Transfer Pricing 2023.”

Working seamlessly with our Tax Controversy team, we have significant experience of resolving transfer pricing disputes, managing audit strategies and filing mutual agreement procedure (MAP) requests. We also help with proactive controversy management strategies including advance pricing agreements (APAs) and global defense documentation.

Our economists provide a range of valuation services that meet tax, financial reporting and business needs, including for restructuring, acquisitions and investor financings. We’ll work within the capabilities of your financial system to develop robust and supportable valuations, whether related to a single entity or a complex chain of hundreds of entities.

For restructurings and intercompany transfers, our appraisals support intangible asset holding companies, principal-based structures, cost share agreements and other tax-based needs. Additionally, we provide shareholder and investment analyses for privately held companies and trusts, including discounts and premiums for control, minority interest, and liquidity issues.

Our Tax and Transfer Pricing teams are recognized as leaders in Chambers and The Legal 500. And we’ve won multiple awards at the International Tax Review awards, with our UK Transfer Pricing team consistently ranked as Tier 1 since 2017.

Our people include former tax officials for governments around the world, and technical advisors for the World Bank, OECD, and IBFD. They’ll get to know your business and they’ll give you comprehensive and legally privileged advice.

Awards and recognition

Experience

Advising a client in the professional services industry on the implementation of a new transfer pricing model involving an innovative UK-EU country cost sharing arrangement to closely reflect the operations of the company and the need for a multi-hub structure. This is combined with an innovative charge-out mechanism to 80+ countries to reflect the value contributed by the hubs.
Advising a leading company in the financial services industry (with a market cap greater than USD50 billion) on transfer pricing models and seeking a bilateral APA between the UK and a European jurisdiction.
Developing a global defense strategy for the global transfer pricing model and supply chain of a US-based multinational health products company with a market cap greater than USD4.5 billion. We assisted the company in implementing the defense strategy across priority jurisdictions and training their local teams.
Assisting a client in resolving a prolonged dispute with the UK tax authority over its intercompany pricing and diverted profits tax position.
Advising a US-based client in the electronic payments industry on a CFO-level strategic project involving the transfer of ownership of more than 100 legal entities to one single Holdco outside the US, to closely align its holding structure with its operations. Valuations were required for both US and Holdco purposes, as well as for local purposes.
Advising a leading fashion brand on the design of a global transfer pricing policy for all of the company’s e-commerce sales. As the company prioritizes the customer’s experience of the sales process, the number of e-commerce opportunities has multiplied at pace. We advised on a streamlined process to identify these different sales channels and create policies that are sustainable even as new channels arise, and simplified enough to not create an undue implementation burden.
Assisting a leading European group in the media sector with optimizing the existing liquidity between the different jurisdictions in which the group is present, by revising the operating model to align it with the transfer pricing policies it had been applying, thus improving the cash collection system. Many of the Group's subsidiaries were in Latin America, so one of the key aspects was the implementation of new policies, adapting them to the different restrictive tax systems.
Advising a client on the value of intangible assets moved into a cost share after acquisition of a third-party business. In addition to providing a valuation, we filed bilateral APA applications with Swiss, UK and US competent authorities regarding the value of these assets and other ongoing cross-border transactions.
Advising a Fortune 500 rating agency on Brexit-related operating model changes for a US MNE resulting from regulatory changes driven by Brexit. We filed a bilateral APA between the UK and France with respect to one of the transactions.