Transfer pricing

We provide advice on related-party transactions, both nationally and internationally, bearing in mind that, from the perspective of transfer pricing, related-party transactions, between different companies in the same business group must be carefully analysed and valued at arm’s length when determining the taxable base of each of the entities making up the group.


The advice includes planning corporate restructurings, carrying out the comparability analysis of related-party transactions, the preparation of mandatory documentation, as well as the negotiation with the Tax Administration of preliminary valuation agreements (APA). We also design and review transfer pricing policies and assess related-party transactions based on the arm’s length principle.

In particular, we take care of the following matters:

  • Analysis and valuation of related-party transactions.
  • Preparation of transfer pricing documentation.
  • Review and preparation of transfer pricing policies.
  • Negotiation of preliminary valuation agreements before the Tax Administration.