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Start-ups, Scale-ups
and Projects of Internationalization

Transfer Pricing for Start-ups, Scale-ups and Projects of Internationalization

The start-up and scale-up sector is placing an increasing interest and effort on the strategic analysis, definition and implementation of actions focused on the internationalization of their activities, with implications on the transfer pricing aspects of the business models and related party charges. This raises the need to establish a solid framework that allows for development through a stable and sustainable model in the medium and long term.

Our sector experts may provide assistance in the following matters:

  • Tax analysis of the best operative model based on the target jurisdictions, optimization or (re)modelling.
  • Analysis of the level of indebtedness and cost of financing that can be considered acceptable from a transfer pricing perspective.
  • Implementation of management and other support service charges.
  • Determination of the profitability attributable to sourcing centers or commercial agents.
  • Analysis of the implications of Pillar I on marketing and distribution activities.
  • Remuneration of the R&D processes and the intangible assets generated and exploited.
  • Elaboration of the contracts that regulate the intragroup operations and financing.
  • Elaboration of the transfer pricing documentation (Local File and Masterfile).
  • Tax reporting, such as local corporate tax forms.

May we help you?

Should you wish to discuss further, please contact
our start-ups, scale-ups and projects of internationalization sector transfer pricing experts

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