Principle :

The transfer price is the price “at which a company transfers either tangible or intangible assets, or proposes services, to associated companies”.

This price is subject to close scrutiny from local tax administrations who verify that the prices are fully competitive and do not include a profit transfer between companies nor, above all, from one country to another.

Our intervention aims to demonstrate the fairness of transfer pricing, notably on brand or patent licence fee rates…

Applicability

• Set up of the transfer pricing brief;
• Assistance in the event of fiscal litigation.

Method

Our approach to transfer pricing analysis follows the OECD recommendations, comprising:

• A functional analysis regarding the role of the related companies, the risk they are willing to take as well as both tangible and intangible assets they are using.
• The use of methods recommended by OECD, notably the comparables method or the functional analysis methods.

We use the comparables method to assess licence fee rates on brands, patents or know-how.

When these methods are not applicable – or only as a complement – we use an analytical approach enabling us to estimate the licence fee rate from the Key Factors of Success (KFS), from the mark-up ratio and the part of the targeted intangible asset compared to other assets.

Results

• Recommendation for setting a licence fee rate or other types of transfer pricing
• Assistance in case of litigation

We helped them :

 Colgate, Georgia Pacific, Lotus, Okay, Palmolive, Soupline...