The development of a transfer pricing policy must satisfy the double objective of both strategic management and security:
- A global and operational approach: transfer pricing policy implementation in line with the operational organisation of the group and consistent across all the jurisdictions in which your company operates, more particularly through our own global network,
- A pragmatic and strategic approach:
- Allocation of profits and risks between the different entities of the group which is consistent from an international regulations point of view and in consideration of the location of the assets and key personnel (“substance”),
- The prior validation of your transfer pricing policies by the relevant tax authorities (“Advance Pricing Agreements”).
- A dynamic approach: the development of a transfer pricing policy that meets the needs of international groups and their constantly changing environments (e-business, big data, etc.).
