Due to the recent developments in (worldwide) taxation, it has become vital for your transfer pricing structure to be flawless and sufficiently supported with properly constructed transfer pricing documentation. We will help you to develop a robust transfer pricing structure that will be correct in tax terms and will impact your business model as little as possible. We have rich experience in setting up and designing robust transfer pricing structures that are closely aligned with the international nature of our clients’ organizations. We are also well aware of the implications of any structural changes for your corporate tax and VAT position. This holistic approach makes us a full-service provider with an access to various international networks, and global coverage. Nowadays, an efficient and effective tax planning simply cannot prevail without a strong underlying transfer pricing foundation. Our team will conduct a thorough study of your business model and strategy in order to grasp the full picture of your needs and, more importantly, all possibilities available. This process is a foundation for arriving at an appropriate, tax-efficient and sustainable transfer pricing model which will be well suited for your business. We are happy to guide you through the process of implementation of your transfer pricing model to ensure that your structure is robust and remains sustainable for years. We have rich experience in areas such as:
Be in control of your transfer pricing strategy Setting-up and maintaining a balanced, well-thought and robust transfer pricing strategy is one of the fundamental challenges underpinning the overall tax position and strategy of a multinational business. If designed and implemented properly, it will not only structure your global profit allocation but also can constitute a complementary and harmonious component of the legal and accounting dimensions of the business as well as a useful framework for your operations and supply chain.
STP will help you succeed in achieving your goals While being experienced in designing operational transfer pricing models for our clients in harmony with their business intuition, we are proud to apply a tax “360 approach” and be mindful of the overall tax impact of the desired operational model (such as value added taxes, withholding taxes, and corporate income tax). Due to our integrated approach (incorporating all tax disciplines), we are always focused on finding the approach that delivers sustainable solutions for our clients, rather than pursuing short term fixes at the expense of long-term benefits. Would you like to learn more? Do not hesitate to get in touch with one of our team members.
Be in control of your documentation and compliance Maintaining tailored and complete transfer pricing documentation compliant with the specific reporting requirements is essential for remaining in control of your tax position as well as minimizing the risk of penalties and being prepared for tax audits. Given the current complex climate of global documentation requirements, it is important to deploy a conscious compliance strategy that, being both pragmatic and cost efficient, aligns with your risk appetite and be suitable for the needs and complexity of your case. Such a strategy should be maintained, whether it is for compliance purposes, audit defense or M&A support.
STP will help you succeed in achieving your goals We have vast experience in preparing fully compliant as well as sustainable transfer pricing documentation and reporting structures, meeting the international and Netherlands- specific requirements. STP provides a variety of solutions, including the preparation of documentation for compliance and audit support aimed at providing our clients with pragmatic, cost efficient and risk mitigating compliance solutions. Our team will help you build, implement and update transfer pricing documentation which will ensure sustainable maintenance and an uncomplicated updating process, taking into account the specific requirements of your company and local regulations. Would you like to learn more? Do not hesitate to get in touch with one of our team members.
Be in control of your benchmarking According to the international transfer pricing standards, the arm’s length nature of all transactions between related parties needs to be substantiated with a data driven study (benchmark) proving the comparability between the features of intra-group transactions and third-party practices in comparable transactions. This requirement applies to all types of intra-group transactions, including regular supply chain relations (for production, sales or service transactions), exploitation of (intangible) assets as well as financial arrangements. Benchmarking requirements are closely intertwined with documentation, as they are the concluding piece of your transfer pricing position, both for transfer pricing compliance and audit defense.
STP will help you succeed in achieving your goals STP has extensive experience in conducting benchmarking studies for all types of transactions. Our team will assist your business in ascertaining the benchmarking parameters as well as performing analyses in line with the underlying design. The analyses and results can be used to support the (advance) price setting and the (subsequent) validation of the arm’s length standard for compliance and audit purposes. We are well aware of the compliance obligations linking to benchmarking studies. Therefore, we always perform economic analyses that meet the highest compliance standards. Would you like to learn more? Do not hesitate to get in touch with one of our team members.
Be in control of your implementation and governance Even the most sophisticated and thought-through transfer pricing policies cannot transform into operational success without proper implementation and continuous governance. Implementation of a transfer pricing policy requires seamless integration of the policy with your business’ administrative, operational, legal and financial procedures and processes. Practices inconsistent with your transfer pricing policies may result in serious challenges made by tax authorities, potentially resulting in transfer pricing adjustments, double taxation, interest and penalties. Correct implementation and application of your policies minimizes these risks.
STP will help you succeed in achieving your goals STP has the knowledge and expertise to guide you through the entire transfer pricing process, from record (setting the prices) to report (evaluate, adjust and report the prices). Our approach enables you to be in control of your operational transfer pricing, whilst dealing with all relevant aspects such as legal, VAT and customs, as well as appropriate reporting (for corporate tax purposes). STP can, like no other, provide assistance in monitoring, adjusting and defending your transfer pricing policy. Would you like to learn more? Do not hesitate to get in touch with one of our team members.
Be in control of your dispute prevention and resolution Increasing documentation requirements, legislation on transparency and exchange of information by local authorities have led to a growing number of (complex) tax audits and disputes. Lengthy and complicated discussions and disputes can result in double taxation and can be time-consuming and costly. The prevention and resolution of disputes are therefore imperative to deal with these challenges.
STP will help you succeed in achieving your goals Our team of transfer pricing specialists has vast experience in the prevention and resolution of disputes with the Dutch tax administration. STP can provide you with assistance and advice in requiring advance certainty (in the form of an advance pricing agreement) or with dispute resolution at a later stage of the discussion with the tax authorities. Our team possesses the right knowledge and skills, weighing the legal and technical aspects of the case, to efficiently and effectively deal with your transfer pricing audits and disputes. Their strong experience enables them to determine the right strategy and deal with each individual case with a balanced approach in line with the complexity of the case. Would you like to learn more? Do not hesitate to get in touch with one of our team members.
Be in control of your restructurings and M&A Today’s business environments are changing rapidly, and success requires the ability to adapt to these changes and restructure your business accordingly. However, business changes, such as restructurings, post-merger integrations, acquisitions or the implementation of a new operational or transfer pricing model are often seen as high-risk areas in the field of transfer pricing. These challenges can best be dealt with by means of solid and sound transfer pricing policies, support and documentation before, during and after the business changes. Suitable transfer pricing support in line with the complexity of your specific case aims to mitigate the challenges in the field of restructurings and M&A.
STP will help you succeed in achieving your goals STP experts are frequently involved in advising clients on business restructurings, ranging from valuations of the transferred asset or technology to supporting the change of transfer pricing model post-restructuring and discussing the tax impact with local authorities. Our solutions are always aimed at seamless integration with your business needs and tax strategy, while, at the same time, mitigating the tax risks and challenges of these types of transactions. Whether you need support with restructurings or M&A, STP ensures all relevant transfer pricing aspects are dealt with. Would you like to learn more? Do not hesitate to get in touch with one of our team members.
Be in control of your valuations The valuation of a business or (intangible) asset can be a crucial part of an investment, takeover or restructuring. The valuation of businesses, (intangible) assets or alternative investments can have major tax implications. The use of economic and financial analysis techniques that are in line with recommendations and approaches of tax authorities is one of the main conditions to maneuver in the fields of valuations for tax purposes. Given that (minor) changes in the valuation could ‘make or break a transaction’, a well-thought and supported valuation approach is a critical pillar for a successful acquisition, takeover, investment or transfer for tax purposes.
STP will help you succeed in achieving your goals Our team has vast experience with all valuation techniques and methods to successfully guide you through strategic acquisitions, takeovers, business or asset transfers. Together with our corporate income tax, private clients and M&A practitioners, we apply an integrated approach and address all tax implications concerning the valuation. If you need a valuation for advance certainty, a dispute or emigration, STP has an excellent track record with these valuations. Would you like to learn more? Do not hesitate to get in touch with one of our team members.
Be in control of your financial transactions Well organized intra-group financial arrangements (relating to working capital, investments or reorganizations) are some of the most material transactions and are an important element for a successful business. They are also an increasingly important area within transfer pricing attracting more and more attention as well as scrutiny from tax administrations around the globe. This is why it is essential to design, analyze and implement robust transfer pricing strategies with respect to intra-group financial transactions, including loans, guarantees or cash-pooling. Not only to remain in full control and compliance with increasingly complex inquiries of the tax offices, but also to meet your business objectives.
STP will help you succeed in achieving your goals Whether you are in need of an analysis of a single intra-group loan or require a more complex intra-group financing structure, our specialists are there to help you succeed. STP has extensive experience in designing, evaluating, analyzing and implementing financial transactions projects ranging from single intra-group loans to complete and sustainable treasury policies and strategies. Would you like to learn more? Do not hesitate to get in touch with one of our team members.
Be in control of your (internal) transfer pricing function and projects Co-sourcing (collaborative sourcing, a mix between out-and in-sourcing) is one of the best approaches to manage your transfer pricing function. It allows your business to benefit from an experienced, outsider’s perspective, network, and resources, and employ an in-house professional to manage the day-to-day aspects of the transfer pricing function. This way you can easily allocate and delegate work in-house or to the external transfer pricing advisors, which will allow you to substantially increase flexibility in dealing with your seasonal and cyclical workload. This also applies to the spike in ad hoc workload, in the event of audits, disputes and acquisitions, where the flexibility of resources and the help of renowned transfer pricing support can be decisive in successfully dealing with these challenges.
STP will help you succeed in achieving your goals At STP, we have extensive experience in supporting your corporate tax or transfer pricing department with transfer pricing challenges, whether this is in a traditional advisory role or on a co-sourcing basis. With profound knowledge in the field of transfer pricing, we deliver tailored solutions aimed at meeting the needs and complexity of your transfer pricing projects. This will allow you to be in control of your on-going transfer pricing projects as well as your ad hoc time-consuming transfer pricing challenges, whilst leveraging from the knowledge, experience and network of a seasoned transfer pricing advisor. Would you like to learn more? Do not hesitate to get in touch with one of our team members.
Be in control of your tax incentives The innovation box is a beneficial tax incentive for innovative activities. Due to the complex common practice, it is not always easy to properly benefit from the innovation box regime. Starting negotiations with the tax authorities without a solid strategy or experienced advisor is one of the main pitfalls in the application of the innovation box regime. With the help of both, these processes can be dealt with more effectively and helps to achieve your company goals.
STP will help you succeed in achieving your goals As innovation box specialists, we maintain good contacts with the tax authorities and look beyond just the tax picture, including the concurrence with your transfer pricing issues. Thanks to our many years of experience with innovation box projects, as well as transfer pricing, we are experts in this field. Due to our extensive experience in innovation box projects, we can determine the best strategy. Together we chose: the right strategy, most beneficial timing, project planning in accordance with your business’ growth plan and potential, the best exit strategy and seamless integrations with your transfer pricing policy. Would you like to learn more? Do not hesitate to get in touch with one of our team members.
Client Cases
Our Specialists
Due to the recent developments in (worldwide) taxation, it has become vital for your transfer pricing structure to be flawless and sufficiently supported with properly constructed transfer pricing documentation. We will help you to develop a robust transfer pricing structure that will be correct in tax terms and will impact your business model as little as possible. We have rich experience in setting up and designing robust transfer pricing structures that are closely aligned with the international nature of our clients’ organizations. We are also well aware of the implications of any structural changes for your corporate tax and VAT position. This holistic approach makes us a full-service provider with an access to various international networks, and global coverage. Nowadays, an efficient and effective tax planning simply cannot prevail without a strong underlying transfer pricing foundation. Our team will conduct a thorough study of your business model and strategy in order to grasp the full picture of your needs and, more importantly, all possibilities available. This process is a foundation for arriving at an appropriate, tax-efficient and sustainable transfer pricing model which will be well suited for your business. We are happy to guide you through the process of implementation of your transfer pricing model to ensure that your structure is robust and remains sustainable for years. We have rich experience in areas such as:
Client Cases
Our Specialists
