Calderwren
Tax Structuring & Transfer Pricing
Strategic tax optimization and transfer pricing solutions for multinational enterprises and complex cross-border transactions
Overview
Our Tax Structuring & Transfer Pricing practice provides comprehensive legal and strategic guidance for multinational enterprises navigating complex international tax landscapes. We specialize in designing tax-efficient structures, implementing robust transfer pricing policies, and ensuring compliance with evolving global tax regulations while optimizing business operations and minimizing tax risks.
With deep expertise in OECD guidelines, BEPS initiatives, and domestic tax regulations across multiple jurisdictions, our team delivers innovative solutions that balance tax efficiency with commercial substance and regulatory compliance requirements.
Our Services
International Tax Structuring
Design and implementation of tax-efficient international structures, including holding company arrangements, financing structures, intellectual property migration, and cross-border reorganizations with commercial substance.
Transfer Pricing Strategy
Comprehensive transfer pricing policies, economic analysis, benchmarking studies, documentation requirements, and defense strategies for intercompany transactions across multiple jurisdictions and business models.
BEPS Compliance & Planning
OECD BEPS implementation guidance, Action Plan compliance, country-by-country reporting, master file preparation, and strategic planning to address base erosion and profit shifting challenges.
Tax Controversy & Disputes
Transfer pricing audits, advance pricing agreements (APAs), mutual agreement procedures (MAPs), competent authority proceedings, and resolution of international tax disputes and double taxation issues.
Key Expertise
Cross-Border Structuring
Multi-jurisdictional tax planning, treaty optimization, permanent establishment planning, and structuring of cross-border investments, acquisitions, and joint ventures with optimal tax efficiency.
Intellectual Property Taxation
IP migration strategies, patent box regimes, development, enhancement, maintenance, protection and exploitation (DEMPE) analysis, and tax-efficient IP holding structures.
Financial Instruments & Derivatives
Tax treatment of complex financial instruments, hybrid arrangements, derivatives taxation, debt-equity characterization, and structured finance tax optimization.
Digital Economy Taxation
Digital services taxes, virtual permanent establishments, digital business model taxation, and compliance with emerging digital economy tax regulations and Pillar One initiatives.
Transfer Pricing Methods
- Comparable Uncontrolled Price (CUP) method analysis
- Resale Price Method (RPM) and Cost Plus Method (CPM)
- Profit Split Method (PSM) for integrated operations
- Transactional Net Margin Method (TNMM) applications
- Value chain analysis and profit attribution studies
- Economic modeling and statistical analysis
- Benchmarking studies and database searches
- Risk analysis and capital allocation methodologies
Specialized Tax Areas
Corporate Restructuring
Tax-efficient mergers and acquisitions, spin-offs, liquidations, cross-border reorganizations, and post-acquisition integration with optimal tax outcomes and minimal friction costs.
Supply Chain Optimization
Global supply chain restructuring, principal company models, limited risk distribution arrangements, and operational transfer pricing for manufacturing and distribution networks.
Financial Services Taxation
Banking and insurance taxation, financial transactions tax, regulatory capital optimization, and transfer pricing for financial services including treasury functions and risk management.
Real Estate & Infrastructure
Real estate investment structures, infrastructure project taxation, REITs optimization, property development tax planning, and cross-border real estate transactions.
Jurisdictional Focus
We provide tax structuring and transfer pricing advice across major business and financial centers:
Ready to Optimize Your Tax Strategy?
Our international tax specialists are ready to help you design and implement tax-efficient structures while ensuring full compliance with global tax regulations and BEPS requirements.
Optimize Your Tax Position