Transfer Pricing M&A / Corporate
Mergers and acquisitions (M&A) transactions and the internationalization processes of companies require an exhaustive analysis of the transfer pricing guidelines that should be incorporated into the due diligence and planning processes of these corporate transactions.
Special Transfer Pricing Restructuring Reports
We have lawyers and economists specialized in the analysis and validation of corporate, M&A and internationalization operations that, from a Transfer Pricing tax point of view, imply the existence of a restructuring whose justification and rationality must be proven before the Tax Agency. Likewise, we assess the possible requirement or not by the tax authorities of compensation for loss of future profits and assist in the reformulation and/or adaptation to the new structure of the Transfer Pricing policies in force up to that moment, all following the guidelines established by the OECD in chapter IX of its Guidelines.
Transfer Pricing Due Diligence
We perform due diligence processes in Transfer Pricing in order to analyze, identify and quantify the possible risks that may exist in a company as a result of non-compliance with existing documentation and reporting obligations. Likewise, we analyze the suitability of the Transfer Pricing policies applied by the target companies in order to set the risk of adjustment and tax contingencies in case of verification by the tax authorities.
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News
Law 16/2022, of September 5, 2022, on bankruptcy reform. Published in the Official State Gazette of September 6, 2022.
Consulta Vinculante V1401-22, dated June 15, 2022 of the Subdirección General de Impuestos sobre el Consumo (General Directorate of Consumption Taxes)
Tax Novelties of the Foral Regulation 8/2022, of July 20, 2002
PKF Attest advisor in the sale of Fervilor Michels and Balsapack Hispania to Innometal
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