Service 04 · Cross-Border Value
Transfer Pricing & International Structuring
Transfer pricing has become the dominant cross-border tax discipline.
It is increasingly analytical, increasingly contested, and increasingly central to how multinational groups, family offices and private capital structures are evaluated by tax authorities and counterparties alike.
We advise on the structural and operational design of cross-border arrangements — and on the policies, documentation and dispute support that follow.
Functional & Value Chain Analysis
Functions & DEMPE
Development, Enhancement, Maintenance, Protection and Exploitation of IP & intangibles.
Economic Reality
Reconciliation between contractual risk allocation and actual decision-making capacity.
Benchmarking & Defensibility
Local & regional comparables data defensible in APA, MAP, or audit controversy.
What we do
Aligning contractual form with functional substance, economic reality, and defensible benchmarking.
Transfer Pricing Policy & Methodology
- Policy design across goods, services, financing, royalties, IP, and capital flows.
- Method selection and benchmarking strategy across APAC and broader footprints.
- Coordination of policy with operational reality (contractual vs economic substance).
Documentation & Compliance
- Master file, local file and Country-by-Country Reporting (CbCR) preparation and review.
- IRAS transfer pricing documentation alignment.
- Documentation refresh for groups whose footprint or value chain has changed.
Disputes & Controversy
- Audit defence and information request management with IRAS and regional authorities.
- Advance Pricing Arrangements (APAs) — strategy, preparation, and negotiation.
- Mutual Agreement Procedures (MAP) and competent authority coordination.
International Structuring
- Cross-border operating model design — principal structures, hubs, IP and financing platforms.
- Treaty interaction and withholding tax pathway design.
- Pillar Two impact assessment on existing and proposed TP structures.
When the work is engaged
- Group restructuring, market entry, divestment or post-acquisition integration where TP architecture is in motion.
- Pillar Two implementation forcing structural reassessment.
- IRAS or regional authority enquiry, audit or APA negotiation.
- Family office or fiduciary platforms where intra-group financing, IP or service flows have grown without coordinated TP policy.
Arrange a Confidential Discussion
All enquiries are handled directly by Michael Velten under strict confidentiality protocols.