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Transfer pricing issues are at the forefront of international tax concerns to document intercompany transactions and comply with the arm’s length standard. The transfer pricing regulatory environment is undergoing significant changes, notably due to the OECD/G20’s Base Erosion and Profit Shifting (“BEPS”) project, the Taxation of the Digital Economy initiative and the impact of the COVID-19 Global Pandemic.

Together, we can develop and support strong and sustainable transfer pricing and international tax solutions that work for you.

Our firm’s Transfer Pricing Practice

Thank you for your interest in STI TAXAND. Our firm was born from the decision of a few tax advisers and fellow Oxford alumni, resident in 3 different continents, to merge their tax practices, joining the Taxand Network, and offering a bench strength focused on transfer pricing and international tax capabilities to support clients worldwide. The team has over 20 years of transfer pricing experience, including partnership roles globally located. We prioritise our clients and provide sound and timely responses to meet current and future needs.

Our locations

Cyprus, London, Paris, Luxembourg, Singapore, Hong Kong, Australia, New Zealand, Vietnam and Indonesia.

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Our team of first-class professionals offers a full range of transfer pricing services and strategic integrated tax advice, from major locations to effectively provide solutions for multinational clients.

Economic Benchmarking

With a multidisciplinary and very experienced team, making use of prime software and databases, we conduct economic benchmarking analysis to evaluate the arm’s length nature of intercompany dealings and pricing, be it for manufacturing, distribution, procurement, R&D, support services, management services, treasury, interest rates on intercompany debts or royalty rates on intercompany licensing, to mention just a few.

Financial Operations Transfer Pricing

We have a truly excellent team, multijurisdictional, highly experienced and specialised on intra-group financial transactions, banking, insurance, as well as investment funds and alternative capital. We regularly prepare various modeling exercises and assist in preparing transfer pricing analysis for treasury, intra-group debts, fund management companies, banks, captive insurance, intra-group financial guarantees, cash pooling and related arrangements, and other derivative or non-traditional financial instruments or activities.

TP Policy and Strategy Design

On the basis of solid industry and value chain analyses, to design, implement, evaluate and reconsider group transfer pricing policies, in relation to the relevant activities, the economic circumstances and business strategies of our clients.

M&A / Business Restructurings

Help support our clients in restructuring projects, through strategic advice and transfer pricing documentation, to attain the best sustainable alternatives, keeping ahead of the curve and navigating the regulatory landscape as it evolves.

Attribution of Profits to Permanent Establishments

Many companies operate abroad through branches, and in some cases it is an industry standard, such as in the banking sector. We assist in documenting the attribution of profits to permanent establishments based on the tax treaty in place, domestic law rules and, in particular, when transfer pricing guidance must be applied by analogy.

Transfer Pricing Documentation

We are eager to assist with the preparation of current Transfer Pricing Documentation compliant with local regulations and international standards, detailing the evaluation of the arm’s length nature of intra-group dealings. This includes: Master File, Local File, special purpose reports, Country-by-Country Reporting, as well as providing implementation guidance and support, to correctly reflect the transfer pricing policies in tax returns, intercompany agreements and other corporate fillings.

Valuation Services

We prepare solid valuation reports in particular for businesses, intangible assets, real estate and financial portfolios, for various purposes including reorganisations, litigation and tax rulings.

APAs, Controversy, Litigation Support and Tax Audit Defence

We have an excellent record of successfully obtaining tax rulings and Advance Pricing Agreement (APA) in various countries.We have exceptional experience in providing compelling tax and transfer pricing advice in the context of litigation, as well as in negotiations with various competent tax authorities to diffuse controversies and lead tax audits to a sound outcome, based on a practical approach as much as on sound legal arguments and economic analyses.

Taxation of the Digital Economy

There are various country and international initiatives to change how highly digitalised businesses are taxed cross-border. Transfer pricing is at the centre of the new rules. It is essential to be ahead of the curve, measure and model the tax implications of the measures and of the alternatives available.

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UK/Cyprus: Global Fund Manager (EUR 3bn)

Advising on transfer pricing of the intra-group transactions of the fund companies, and advising on the new risk analysis framework – six step process following BEPS Actions 8-10 for identifying and analysing risks.

UK: Treasury company investing in distressed debt, for a large UK Pension Fund (GBP 7bn)

Transfer pricing evaluation of the interest and gain components related to distressed debt of intermediary financing companies, including the credit evaluation and expected recovery rates of the borrowers.

Cyprus: Trading Platform Valuation (EUR 300m)

Prepared a valuation for the transfer of software for a trading platform and obtained tax rulings in Cyprus regarding the IP regime, and abroad securing tax certainty regarding royalty rates applied.

Asia: Restructuring for Luxury products multinational (>EUR 10bn)

Designed a new transfer pricing global policy for a large Asian multinational operating in the retail business of luxury products, preparing documentation and negotiating various APAs in various countries.

Israel: Valuation of intangibles for an Entertainment and Gaming Group (EUR 100m)

Valuation of various marketing intangibles being sold, in relation to products in the entertainment and gaming industry.

US: Intra-group financing for R&D activities of a major US technology multinational (USD 2.5bn)

Providing transfer pricing advice on structuring various financial instruments through Cyprus, granted from the US ultimately to European subsidiaries of a US technology multinational. The subsidiaries were engaged in “blue sky” (high risk) research and development activities.

Luxembourg / Singapore / Cyprus: Treasury company of major real estate fund (EUR 1.5bn)

Advised on setting-up full-fledged treasury companies in Luxembourg and Singapore of a Cyprus-based regulated fund, investing in Asian and European real estate.

Eastern Europe: TP litigation support for Original Equipment Manufacturer (OEM) (EUR 400m)

Developed a transfer pricing model to map, in particular, key functions and intangibles explaining the group’s profit allocation, successfully employed in the context of tax litigation for a OEM operating in Eastern Europe.

Netherlands / Belgium: Transfer of portfolio of loans from a Private Bank provided to online entertainment start-ups (EUR 3bn)

Advised on the transfer of a large portfolio of intra-group loan receivables from Belgium to the Netherlands, and negotiated an APA with the Dutch tax authorities. The loans had been granted to online gaming and online casinos start-ups, and the project included a valuation of the gain realised upon the transfer of the portfolio of loans.

LATAM: Parent guarantees to issue bonds to the market to acquire a pharma Company in LATAM (USD 2bn)

Advised on the transfer pricing aspects of parent company financial guarantees, including an element of performance guarantee, to issue bonds to the market and use the proceeds to acquire a LATAM pharmaceutical.

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