We assist multinational companies in developing practical and defensible transfer pricing frameworks tailored to their global operations. This includes identifying appropriate pricing methods, benchmarking against reliable comparables, and determining arm's length profit margins. Our team prepares contemporaneous documentation—including master files, local files, and special issue reports—that clearly outlines the business context, pricing rationale, and transactional details. We also closely monitor BEPS implementation, evolving OECD guidance, and jurisdiction-specific APA practices to help clients stay compliant and ahead of regulatory risks.
We support clients in negotiating unilateral, bilateral, and multilateral Advance Pricing Arrangements (APAs) to reduce audit exposure and enhance the transparency of related-party transactions. Our services cover pre-filing assessments, economic modeling, and communication with tax authorities to secure mutually acceptable pricing terms. We also conduct ongoing risk assessments by benchmarking intercompany profit margins using databases such as BvD and the OECD, and assist in addressing pricing anomalies in a timely and defensible manner.
Our lawyers help clients establish robust compliance systems based on the arm's length principle. We regularly advise on complex ownership structures, multi-tiered related-party arrangements, intangible asset valuation, and the substantiation of intragroup services. With a dual focus on tax optimization and regulatory defensibility, we ensure that transfer pricing strategies are legally sound and resilient to scrutiny across jurisdictions.
We also advise on emerging transfer pricing challenges, such as those arising in digital business models where user-generated value complicates profit allocation, or in global supply chain restructuring where intercompany transactions and pricing frameworks evolve rapidly. ForTran actively collaborates with academic institutions and regulatory bodies on cutting-edge policy research and provides clients with insight-driven strategies for navigating transitions and minimizing risk.
