Marthe Kleinjan
Partner, PwC Netherlands
I advise clients on their worldwide allocation of taxable profit and transfer pricing, i.e. which part of a company’s profit is attributable to which activities on the basis of international and national tax rules and how this profit allocation can be effectuated and substantiated efficiently and effectively using internal transfer prices. This requires a good understanding of the company, its organisational structure and processes, but also the objectives and context of the internal tax/finance function in order to ensure proper consideration and alignment of the transfer pricing model.
As an advisor, I find it important to have a full understanding of my client's strategy so that my advice can contribute positively to it. It is also good to hear what beliefs and assumptions there are regarding the profit allocation and transfer pricing model - in my experience, there are almost always opportunities to achieve simplification and more efficient compliance and to increase certainty around the model applied.
My experience includes the design and adaptation of transfer pricing models, restructuring, implementation, horizontal monitoring, (multilateral/bilateral/unilateral) advance pricing agreements, and defence of profit allocation in tax audits.
Education
- Leiden University - Fiscal law
Memberships & additional activities
- Member of the Dutch Association of Tax Advisers (NOB)
- Board member of the NOB Women's Network
- Guest lecturer at NOB, Erasmus University
