Assets valuation & Business Structuring

Context

Business and legal restructurings within multinational companies involve transfers of businesses, intangibles or shares. Cross-border reorganizations of commercial, financial or legal relations between associated enterprises trigger transfer pricing issues.  

The Arm’s Length Principle, as per Article 9 of the Model Tax Convention applies to these transactions as well as the OECD recommendations for valuation purposes. 

The determination of the arm’s length compensation for the restructuring itself and for the transfers occurring between group member companies is governed by the transfer pricing guidelines issued by the OECD.

Our value proposition

Valuation

We assist our clients with the determination of the fair market value of the business restructurings, business, and assets transfers by implementing the OECD guidance and complying with the arm’s length principle.

We use different valuation methods commonly applied by most of tax administrations and valuation practitioners. Our objective is to secure the business restructurings themselves and we ensure a strict implementation to the transfer pricing requirements set by the OECD and local tax authorities.

Transfer pricing policy post structuring/restructuring/integration

We support our clients throughout the process of restructuring or integrating businesses, from decision-making to the launch of operations. We design tax structuring and transfer pricing models to implement commercial decisions. We support these schemes with economic and tax reports.