International Taxation and Transfer Pricing

Comprehensive Support for Tax and Legal Compliance

Tax and regulatory advisory services

– On-demand advisory (written or verbal) covering tax, customs, foreign exchange, and corporate regulations;

– Preparation of analyses, memoranda, and opinions tailored to client needs;

– Drafting of correspondence and support in interactions with the authorities;

– Attendance at meetings and assistance in discussions with stakeholders;

– At the client’s request, confirmation of research findings and interpretations with the competent authorities.

Transfer Pricing Advisory & Compliance

  • Comprehensive Transfer Pricing (TP) documentation compliant with local regulations, international standards & OECD guidelines.
  • Design & implementation of TP policies tailored to business operations, value chains & applicable tax laws.
  • Strategic support during tax audits & disputes, including preparation of responses & representation before tax authorities.
  • Advance Pricing Agreement (APA) advisory, covering unilateral, bilateral, & multilateral APAs from feasibility to negotiation.
  • Robust benchmarking & economic analyses to support arm’s length pricing of intercompany transactions.

Our engagement in Corporate

In supporting companies with their corporate and tax legal obligations,
we ensure full compliance while minimizing operational risks.

Our engagement in Corporate and Tax legal compliance services covers the full lifecycle of the entity,
from incorporation to ongoing reporting and regulatory requirements.

Pillar Two assistance

Pillar Two refers to the OECD’s Global Minimum Tax framework, designed to ensure that large multinational groups pay a minimum effective tax rate of 15% in every jurisdiction where they operate. The framework introduces the Global Anti‑Base Erosion (GloBE) rules, which compute an effective tax rate (ETR) for each jurisdiction and impose a top‑up tax when that rate falls below 15%.

It applies to multinational groups with consolidated revenues of at least EUR 750 million in at least two of the four preceding fiscal years.

Our firm supports multinational groups in navigating the complex requirements of the OECD’s Pillar Two rules. We help companies assess their exposure, interpret the OECD Model Rules, and align their structures with both international standards and domestic implementing regulations.

Our experts provide end‑to‑end assistance — from diagnostic reviews and strategic planning to compliance implementation. We help clients identify key risks, model effective tax rates, and evaluate the financial impact of the new 15% global minimum tax.

We also assist in analyzing local top‑up tax mechanisms, ensuring consistency with OECD principles and helping clients manage compliance across multiple jurisdictions — including GloBE return preparation, safe‑harbour assessments, and governance documentation.

With deep technical knowledge and regulatory insight, our team guides corporate tax departments through evolving reporting obligations, data‑management challenges, and coordination between headquarters and local subsidiaries.

Our goal is to help organizations anticipate regulatory change, minimize compliance risks, and develop a transparent and sustainable global tax strategy under Pillar Two.