Financial transactions

Throughout the corporate life cycle there is a need to ensure that finance is available to fund key transactions (e.g. acquisitions and significant capital expenditure). We are able to offer tailored solutions with respect to sizing (level of debt and capital structure) and  pricing (appropriate terms and conditions and rates) such financing transactions, often working closely alongside our Debt Advisory practice.

As territories move towards compliance with the revised transfer pricing documentation guidance, clients are requiring specific assistance in complying with the requirements to summarise the key intercompany financing policies under the Master File and the specific transactions and intercompany prices per the Local File. Through our detailed understanding of the rules and requirements, including local country nuances, we are able to deliver compliant, comprehensive documentation in a cost effective manner.

Given uncertainty in the global FTTP landscape, a priority of our clients more recently has been to obtain certainty with respect to the transfer pricing of their financial transactions (taking the form of either unilateral or bilateral negotiations with tax authorities). Drawing on our experience in negotiating such agreements with a large number of international tax authorities, we are able to ensure efficiency and timeliness throughout the negotiation process.

We have seen a significant increase in cases in relation to FTTP over the course of the last ten years, all of which have shaped the way in which tax authorities, and more broadly the OECD, today have sought to assess these transactions. We have experience in assisting clients in the defense of their technical positions under audit challenge, and work closely alongside our Tax Dispute Resolution network more broadly to leverage the broadest possible array of knowledge to assist with negotiations.