Our team of experienced and dedicated project managers make us well suited to transfer pricing documentation and compliance projects of all scopes and sizes. By assigning a single point of contact to each project, we save our clients significant time and effort by streamlining global coordination between BaseFirma offices and alliances and their local client counterparts.

 Our services cover all key components of global transfer pricing documentation, including:

• Transfer Pricing Documentation Reports (both localized and OECD local file format) for all major jurisdictions/regions
• OECD BEPS Master File
• TP Disclosure Forms and Filings
• TP Defense Files and Benchmarking Memoranda

A forward-looking, scalable, and streamlined transfer pricing model is essential for a well-functioning corporate tax function. BaseFirma is skilled and experienced at designing transfer pricing structures that fit your current business realities as well as you vision for growth.

• TP Design and Structuring

We help multinational enterprises design efficient and scalable global transfer pricing structures, including recommendations of intercompany physical, financial, and contractual flows, and identification of intercompany agreements/contracts, setting transfer pricing policies that minimize risk while promoting your company’s objectives.

• Benchmark Analysis

BaseFirma performs quality, timely economic analyses that help guide your company in selecting intercompany transfer pricing policies that comply with the arm’s length standard. These range from CPM/TNMM benchmarking sets of comparable companies to sets analyzing comparable transactions for licenses or royalties.

• Transfer Pricing Strategy

BaseFirma will help you consider transfer pricing strategies from multiple angles, from risk management and compliance to M&A plans and tax efficiency.

• Complex Transactions

Our personnel have extensive knowledge and experience in transfer pricing planning strategies and models spanning all major transaction categories, including complex transaction such as:

– Cost sharing and cost contribution arrangements

– IP migrations and transfers

– Financial transactions

– Shared services charge-outs

Transfer pricing is one of the fastest growing subjects of audits by tax authorities around the world. At BaseFirma, we offer a range of solutions and support to minimize your risk of a potential audit, and to defend your company in the case of an ongoing audit. These services include negotiations of Advance Pricing Agreements (APAs), preparation of defense files, due diligence reviews, and review of intercompany legal agreements, among others.

• Advance Pricing Agreements

BaseFirma can help you with the complex scoping and negotiation processes of unilateral, bilateral, and multilateral APAs. We have leadership with valuable tax administration employment experience, and team members with years of experience dealing with tax authorities.

• Tax Audit Defense

Many of our offices work with prestigious local law firms to research tax cases and establish positions to help you defend you transfer pricing policies and results.

• Defense File

Defense Files generally include the preparation of documentation providing specific evidence supporting your tax and transfer pricing positions.

• Review of Legal Agreements

Our personnel can review your intercompany legal agreements and provide advice on how to improve them for internal or audit-readiness purposes.

• Audit Readiness Analysis

An audit readiness analysis can help your organization anticipate any compliance issues that may arise in the event of a tax or transfer pricing audit. BaseFirma has tools that can quickly and easily provide guidance on your key areas of risk and exposure. Try out our Risk Tool today!

The persistent advance toward data-driven approaches to business functions means that operational transfer pricing – the practice of converting transfer pricing policies into financial statement reality – is one of the most pressing topics for corporate tax departments. At BaseFirma, we understand that transfer pricing structures and policies are only the first step in a complex implementation process, and therefore we offer operational transfer pricing solutions to our clients to automate and ensure quality in monthly, quarterly, and/or annual transfer pricing calculations, as well as to monitor interim results on an ongoing basis.

• Implementation of Transfer Pricing Policies

BaseFirma and our partners can assist you with implementing your transfer pricing policies into your financial and tax statements. This includes support with automating transfer pricing calculations, working within GL or sub-GL level data to tag and categorize accounts, and informing intercompany adjustment or invoice amounts. Our operational transfer pricing service span all major transactional categories, including but not limited to:

– Cost-Plus or Resale Minus Calculations

– Royalty or License Fee Calculations (both fixed and variable)

– Intercompany Service/Cost Charge-out Allocations

– Intercompany Interest or Financing Calculations

• Transfer Pricing Monitoring

We help our clients monitor their transfer pricing results on an ongoing basis, in order to avoid unwelcome surprises at or after year-end.

• Global Coordination

At BaseFirma, seamless cross-border coordination of projects, however large or small, is our expertise. Our project managers will connect and communicate with your local tax managers, controllers and other key personnel, wherever they are located. This ensures consistent implementation of your transfer pricing policies across the board.

Meeting compliance requirements is your first priority and BaseFirma offers software tools that put the power in your hands. We (co)developed TPGenie, BrasilGenie, CbCr Tool, and our Risk Assessment Tool to give you accuracy, consistency, and control.

• • CbCr Tool
    • The Country by Country report is a delicate filing for large multinationals.  BaseFirma’s Country by Country converter is an Excel based tool that helps preparing CbC reports compliant with OECD Schema v2.0.  Before converting to XML format, the tool pre-validates the data, thus reducing instances of filing rejection.  Each conversion to XML takes less than a minute. Additional ratio analyses and risk assessment analyses can be customized based on the CbCr data.

• • BrasilGenie
    • This product was developed to bring nimbleness and to bring agility to the Brazilian TP documentation process.
    • The software reads information provided by the taxpayer and runs transfer pricing calculations according to Brazilian regulations and preparing robust documentation support.
    • BrasilGenie allows preparing Brazilian TP calculations on a monthly basis and exploring scenarios based on the different interpretations of the Brazilian transfer pricing rules.

• • TPGenie
    • The one-stop software for creating and managing Transfer Pricing documentation, including Local Files, Master Files, Benchmarks, Intercompany Agreements, and Country by Country Reporting.
    • TPGenie reduces time spent locally on documentation preparation and makes meeting compliance obligations easier.
    • TPGenie allows for team workflow; you can share and delegate documents and tasks with colleagues using the incorporated status, survey & messaging system.

• • TP Risk Assessment Analysis
    • For Transfer Pricing risk management and control.
    • TP Risk Assessment is the process of identifying the transfer pricing risk exposure deriving from the taxpayer’s intragroup arrangements and determining whether the risk is worth for tax authorities pursuing by conducting a resource-intensive audit.
    • Our TP Risk Assessment analysis uses company, group, industry, and transactional information for scoring TP risk.  It also performs TP Audit Readiness scoring where risk control measures are assessed to create a course of action for TP audit risk control.

Do you know the value of your company’s intangible assets? Whether for the purpose of transferring rights to affiliates or as part of a larger valuation, BaseFirma can assist your company with the identification and valuation of its intangible assets, such as trade names, trademarks, and know-how.

• Debt Capacity for Analysis

A dynamic analysis of the capacity of repaying a loan, necessary to determine the arm’s length size of a loan.

Analyze your financial information and determine the amount of sustainable debt that your company can handle. This analysis can be expanded for senior/subordinate debt structuring.

• Loan Pricing

Using different methodologies and data providers, BaseFirma can assist you in determining the arm’s length terms, the economically relevant characteristics, and the optimal interest rate of the financial transaction.  Multiple comparability adjustments are considered according to the delineation of the transaction, allowing for complex loan structuring.

• Guarantee calculators

A toolkit designed to determine the different attributes of a guarantee arrangement and appropriate guarantee fee, under different methodologies consistent with the most recent OECD Guidelines.

Getting your transfer pricing right requires attention to detail over the entire intragroup transaction lifecycle.  BaseFirma will work together with you tax or transfer pricing department. Together we can handle all necessary document production review and ensure that your in-house documentation is of the highest quality.