By drawing on expertise in both our Transfer Pricing and Securities and Finance Practices, NERA is uniquely positioned to assist in-house practitioners and tax advisors manage risk and deliver value on issues related to treasury services.
NERA's relevant expertise includes:
- pricing financial transactions, including in relation to cash pooling, loans and structured finance, guarantees, leasing, and commodity and FX hedging;
- applying CAPM and other economics-based approaches to thin capitalisation analysis, and assisting clients in obtaining rulings and defending filing positions;
- advising on the design and implementation of transfer pricing models that correspond to different treasury services models (e.g. conduit arrangements, in-house banking, etc.);
- conducting risk assessment exercises and providing recommendations on good practice regarding policy and processes in transfer pricing for treasury services;
- preparing or assisting in the preparation of transfer pricing documentation in line with OECD Guidelines and, where, appropriate, local rules and regulations;
- where not already met by contemporaneous transfer pricing documentation, assisting clients in preparing analyses and/or documentation to satisfy auditors concerning tax provisions;
- providing specialist economics and finance input to support a taxpayers' filing positions where tax authorities have raised queries; and
- providing expert testimony in that event that cases proceed to litigation.