Transfer Pricing Solutions for multinationals, spanning from start-ups to Fortune 500 enterprises: 

Comprehensive approach – tax, legal and economics 

Tax authorities worldwide have increasingly focused on transfer pricing to optimize their tax collection from multinational enterprises. Taxpayers are therefore required  to be prepared for formal reviews and audits by respective tax authorities by establishing that their intercompany transactions are performed at arm’s length and that profits in each of the Group’s entities are aligned with value creation. We offer a proactive approach by ensuring planning documentation in place, in line with the documentation and reporting requirements in each jurisdiction, in order to mitigate the risk of significant transfer pricing adjustments, penalties and interest. 

JH & Co. prepares all forms of transfer pricing documentation, including planning report as well as fully compliant reports and local files. To support each client’s global documentation and compliance needs, we team with a global network of transfer pricing & legal practitioners in all major markets in North America, Europe, Asia-Pacific markets.   

We are highly experienced in leading planning and global documentation for all types of intercompany transactions, including:

• Distribution & Manufacturing.
• R&D functions, including DEMPE analysis when applicable.  
• Intercompany Services.
• Financing (loans, guarantees, cash pooling).
• Use of Intangibles.
• Cost Allocation & Cost Sharing Arrangements. 

We prepare Transfer Pricing documentation to best suit each client’s needs: 

•  Aligned with BEPS requirements in the relevant jurisdictions, we prepare Group Master Files, individual country Local Files, and Country-by-Country Reporting (“CbCR”), as needed.  

• Transfer Pricing Planning Reports. 
• Transfer Pricing Benchmark Analyses and Memorandums. 

Start-up Tax Planning & Pricing Strategy: JH & Co. has vast experience with early-stage companies and offers these services tailored to each company’s needs. When a start-up is ready to ‘go global’, a sound transfer pricing strategy and policies for intercompany pricing is critical. Since corporate tax rates vary in each country, it is therefore important to structure pricing strategies that will be both compliant with transfer pricing requirements in each of the relevant jurisdictions as well as to optimize business and tax planning objectives. JH & Co. recognizes that start-ups must manage and prioritize their expenses and offers transfer pricing planning strategies at competitive, cost-effective packages.