Transfer Pricing

Transfer Pricing Documentation

Transfer Pricing Documentation

NERA's approach to transfer pricing documentation aims to combine compliance-oriented and policy-guiding approaches by developing intercompany pricing policies grounded in sound business strategy and well-established economic principles. Our thorough analysis of the industry structure and its value chain combined with rigorous analytical methodologies and clear presentation of the results allow us to develop transfer pricing solutions that meet both our clients’ business objectives and the arm’s length requirements imposed by national tax authorities.

Masterfile Documentation

A "masterfile" approach to transfer pricing documentation is a practical and cost-efficient solution for MNCs with operations in a group of countries that follow a common set of transfer pricing principles, such as those outlined in the OECD Transfer Pricing Guidelines or in the Pacific Association of Tax Administrators documentation requirements.

Best practices in creating masterfiles combine the centralized approach to documentation development with information gathering and review at the local level. NERA’s global network of transfer pricing experts provides MNCs with the capabilities to utilize our extensive data resources to implement this robust approach.

FIN 48 Support

FASB Interpretation No. 48 (FIN 48) outlines procedures for recognition and measurement of uncertain tax positions in order to record them on financial statements. In a transfer pricing context, the tax benefits are often considered equivalent to the lack of increased income recognition in a given country resulting from transfer pricing adjustments imposed by the local tax authorities. Transfer pricing has a significant impact on FIN 48 disclosures of MNCs.

NERA assists clients with several aspects of FIN 48 implementation including:

  • Reviewing intercompany transactions to determine the appropriate units of account and material income tax positions, and to create appropriate recognition and measurement methods.
  • Providing advice on audit policies and administrative procedures followed by the tax authorities in different countries.
  • Preparing transfer pricing documentation to inform management’s opinion that the tax position will "more likely than not" be sustained upon examination.
  • Setting up measurement procedures that involve calculating the amount of tax benefits related to transfer pricing, projecting alternative outcomes that might be realized in resolving the position, calculating probabilities of realization of each outcome, and cumulative probability analyses.
  • Creating an implementation process to update FIN 48 analysis on a quarterly and annual basis.
Name Title Location Phone Email
Dr. Yves Hervé Managing Director Frankfurt +49 69 710 447 508
Dr. Harlow Higinbotham Managing Director Chicago +1 312 573 2803
+86 21 6103 5544
+86 10 6533 4395
Dr. Emmanuel Llinares Managing Director
Head of Global Transfer Pricing
+33 1 70 75 01 93
+41 22 819 94 94
+44 20 7659 8650
Philip de Homont Director Frankfurt +49 69 710 447 502
Dr. Niraja Srinivasan Director Washington, DC +1 202 466 3510
Dr. Vladimir Starkov Director Chicago +1 312 573 2806
Nihan Mert-Beydilli Associate Director Los Angeles +1 213 346 3035
Yuko Saito Associate Director New York City
+1 212 345 1963
+81 3 3500 3378
Tom Braukmann Principal Frankfurt +49 69 710 447 511
Dr. Alexander Voegele Affiliated Consultant Frankfurt +49 69 710 447 501
Title Type Author
Managing Transfer Pricing in the COVID-Related Economic Downturn Published Article Dr. Harlow Higinbotham, Dr. Vladimir Starkov, Nihan Mert-Beydilli
Germany: The Changing Model of Group Financing Centres Published Article Yves Hervé, Philip de Homont and Georg Dettmann
NERA Experts Offer Insight into OECD Guidance on Financial Transactions White Paper Amanda Pletz, Ralph Meghames and Dr. Georg Dettmann
NERA Contributes to Bloomberg Tax Winter 2019 Transfer Pricing Forum Published Article Dr. Alexander Voegele and Philip de Homont
What Is the Value of Users, Anyway? How to Value the User Contribution to Digital Ent... Published Article Vladimir Starkov and Oceana Wang
Sustaining Contract R&D Service Solutions in a Post-BEPS DEMPE Context Published Article Dr. Yves Hervé, Philip de Homont
Implicit Support and Its Implications on Guarantee Fee Pricing: Fact or Fiction Published Article Amanda Pletz, Gary Lambert, Dr. Georg Dettmann, and Diana Kabir
NERA Experts Comment on the OECD Proposal for a “Unified Approach” under Pillar One Regulatory Filing Dr. Vladimir Starkov, Dr. Yves Hervé, Amanda Pletz, Dr. Emmanuel Llinares, Dr. Harlow Higinbotham, Pim Fris and Dr. Jacques Potin
How to Adapt to the DEMPE Concept When Using Third-Party Licensing Agreements for Tra... Published Article Dr. Yves Hervé, Philip de Homont
Transfer Pricing Challenges in the Digital Economy: A Case Study of the Internet of T... Published Article Dr. Niraja Srinivasan