Financial services and transactions transfer pricing

Transfer pricing is definitely in the spotlight, both for financial transactions (FT) within multinationals in all industries, and for transactions specifically within financial services (FS) companies. In these complex areas of transfer pricing, companies have to deal with the current, more stringent requirements, and a tough audit climate. This complexity is only expected to increase, considering the evolving regulatory landscape driven by OECD and the European Commission, and specific approaches and guidance being released by local tax authorities. How will you ensure that your transfer pricing policies are in accordance with the latest guidance, requirements, and relevant developments?

FT TP for multinationals in all industries and FS companies

In the area of FT, our team of experts supports multinationals in different industries with robust policy design, tooling and technology to ensure that the transfer prices of financial transactions remain at arm’s length. 

For clients in FS, we leverage from our broad expertise and knowledge in the industry and the specific intercompany transactions that occur within such companies. 

PwC Netherlands is market leader in both FT and FS transfer pricing.

How PwC can help

We can support you with your in-house finance policy design, by incorporating treasury procedures and frameworks, benchmark technology, documentation templates, and implementation support. We have extensive expertise and a comprehensive suite of services in FT and FS transfer pricing.

FT transfer pricing 

  • Policy design combined with tooling and technology.

  • Design and documentation of cash pool policies.

  • Support in controversy and dispute matters arising from the challenges posed by local tax authorities with respect to complex inter-company financing structures. Our team has a unique and extensive track record in FT transfer pricing disputes and litigation.

  • Financial modelling and quantitative analyses to find risks and mitigate solutions.

FS transfer pricing for banks, insurers, market makers, asset managers, etc.

  • Real estate acquisition funding, including loan-to-value (LTV) testing and related financial modeling, finance structuring and interest rate benchmark analyses.
  • Design and support of transfer pricing models in relation to fund structuring, asset management, head office services, (re)insurance transactions, (global) lending, intangibles and technology (including the application of the innovation box), profit allocation to (server) PEs, and more.

Expertise on tax, real estate, legal and treasury

We actively collaborate with our specialist colleagues from the FS tax, legal and treasury consultancy teams, which allows for a comprehensive and end-to-end service offering. Technology is increasingly relied upon to create efficiencies and optimizations, but is also offered for in-house use and policy implementation purposes. This enables you to be in control of the pricing of your loans and cash pool transactions, for instance.

Follow us