This M&A/deals focused Transfer Pricing team provides specialist Transfer Pricing input on live transactions (including due diligence and structuring which involved debt pricing), as well as supports the clients post-deal through to preparation for the exit. This includes Transfer Pricing / operating model design, advisory on the specific Transfer Pricing and permanent establishment topics, TP documentation, tax audit defence and advanced pricing agreements.
Responsibilities
- Working with the Deals Tax practice as a subject matter specialist providing input in diligence and structuring
- Undertaking Transfer Pricing / operating model review and design, as well as assisting the clients with the model implementation
- Involvement and coordination of European and global Transfer Pricing engagements working with specialists across our global network
- Supporting companies through all elements of business change and value chain transformation (e.g. implementation of centralised or principal structures, Intellectual Property model design)
- Preparation and negotiation of Advance Pricing Agreements on behalf of clients
- Assisting clients with tax audits from HMRC and Transfer Pricing defence strategies; and preparation of Transfer Pricing documentation for planning or compliance purposes
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