Transfer Pricing Compliance

As multinational operations grow, so does regulatory scrutiny. At Borderless Lawyers, we help companies develop and maintain transfer pricing compliance strategies that align with international standards, protect against audits, and support tax efficiency across jurisdictions.

Whether you’re pricing intercompany goods, services, IP, or financing arrangements, we ensure your transfer pricing policies meet local and OECD guidelines—while reinforcing the legal and commercial logic of your structure.


✅ What We Offer in Transfer Pricing Compliance

📄 Transfer Pricing Policy Development

  • Design defensible pricing models for intercompany transactions

  • Apply OECD arm’s-length principles across business functions

  • Customize policies for goods, services, royalties, and cost-sharing agreements

📑 Documentation & Local File Preparation

  • Prepare required master files, local files, and country-by-country reports (CbCR)

  • Ensure documentation meets local regulatory formats and language requirements

  • Coordinate with tax and legal teams to align with commercial realities

🧾 Intercompany Agreements & Legal Structuring

  • Draft and review intercompany contracts (IP licenses, services, financing)

  • Align legal form with substance to withstand regulatory and audit review

⚖️ Risk Assessment & Audit Readiness

  • Identify high-risk jurisdictions, transaction types, and value chains

  • Simulate audit scenarios and support with defense strategy preparation

  • Coordinate with external advisors or in-house tax teams during reviews


🛠 How We Work

🧭 1. Transaction & Risk Mapping
We review your global operations, value chain, and intercompany flows to identify exposure points.

📄 2. Policy Design & Documentation
We develop robust transfer pricing models and prepare compliance documentation for each jurisdiction.

⚖️ 3. Contract Drafting & Alignment
We draft or update intercompany agreements to support the tax and legal position.

🔍 4. Ongoing Monitoring & Adjustments
We help adapt your pricing and documentation as business models and regulations evolve.


👥 Who We Help

  • Multinational groups with cross-border operations

  • High-growth companies expanding into multiple jurisdictions

  • Businesses involved in IP licensing, intercompany services, or cross-border financing

  • CFOs, tax managers, and legal departments seeking full legal coverage


✅ Why Borderless Lawyers?

🌐 In-depth knowledge of OECD BEPS rules and local TP regulations
📜 Integrated legal-tax approach for both structuring and compliance
⚖️ Strategic risk mitigation to prepare for audit scrutiny
🔐 Confidential, tailored support for small groups and large multinational enterprises


📞 Protect Your Group With Proactive Transfer Pricing

Contact Borderless Lawyers to build a compliant, audit-ready transfer pricing framework that supports your global operations without triggering unnecessary tax exposure.

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