International transfer pricing

International transfer pricing

 

As global tax regulations tighten and scrutiny increases, businesses must ensure their
intercompany transactions are priced in line with the arm’s length principle.

Our international transfer pricing services are designed to help multinational groups achieve compliance, manage tax risk, and align their pricing policies with commercial reality, including within Irish and EU regulatory frameworks.

Compliance and documentation

We assist clients in meeting Irish and OECD transfer pricing documentation requirements, ensuring full compliance and audit readiness:

✅  Preparation of Local Files and coordination of Master Files in line with BEPS Action 13.
✅  Country-by-Country Reporting (CbCR) support.
✅  Preparation of intercompany agreements and annual TP reports

Benchmarking and economic analyses

Our benchmarking services establish defensible arm’s length ranges for your group’s transactions:

   Comparable studies for management fees, services, royalties, and financing.
   Margin and profit-level indicator (PLI) analysis.
   Application of OECD-approved methods (CUP, Cost Plus, TNMM, Profit Split).

Strategic and advisory services

Beyond compliance, we help businesses design transfer pricing policies that align with strategic and commercial goals:

✅  Policy design and implementation across global operations.

✅  Review of group structures and cross-border efficiencies.

Dispute management and risk mitigation

 

Our team provides:

 

✅  Experienced support for managing tax authority disputes

 

✅  Including Revenue enquiry response and audit defence.

Intangible property and ip planning

Our specialists advise on the valuation and pricing of intangible assets, ensuring alignment with OECD DEMPE principles:

→   Royalty and licence pricing.
ƒ →   IP transfers and valuation.
ƒ →   Support for innovation incentives such as the Patent Box.

Training and capacity building

We offer tailored training sessions for tax and finance teams on:

✔   Transfer pricing principles

✔  Compliance

✔  Documentation best practice

Our approach

 

Our multidisciplinary team combines tax, economics, and legal expertise to deliver practical, defensible solutions.

 

We work with clients across sectors to ensure compliance, optimise tax efficiency, and strengthen global value chains across Irish and international operations.

 

Let’s get started

 

For a free consultation and analysis of the potential returns you might expect from your projects, contact the ABGi Ireland Team.