Tax Law · European Union
Defend Your Transfer Pricing Arrangements With a Specialist Who Knows the Benchmarks
If your group trades across borders, the prices charged between its entities are under growing scrutiny — and a challenge can unwind years of profit allocation. We match you, free of charge, with a transfer pricing lawyer who handles documentation, advance arrangements and disputes across Europe.
- Lawyers who specialise in transfer pricing
- Coverage across the EU & EEA
- No fee to get matched
No commitment. No hidden fees.
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Who this is for
Transfer pricing is where multinational tax risk concentrates — and most groups are under-prepared for it
Transfer pricing governs the prices charged between related companies within the same group for goods, services, intellectual property and financing. Because these prices determine where profit is recognised, tax authorities scrutinise them closely to ensure the allocation between countries reflects what independent parties would have agreed — the arm’s length principle. For any business operating across borders, this creates three demands at once: documentation that justifies the pricing, a defensible method for setting it, and the capacity to argue the position if an authority challenges it. The rules are aligned across much of Europe but applied differently in practice, and an adjustment in one country can create double taxation unless it is resolved through the proper channels. A specialist lawyer builds and defends your transfer pricing position before it becomes a dispute.
Why businesses get caught out
Transfer pricing disputes are built on documentation.
Most groups only discover the gap when it is too late.
A pricing arrangement that has run unchallenged for years can be re-examined and adjusted retroactively, with penalties on top.
No defensible documentation
Authorities increasingly expect contemporaneous documentation showing how intercompany prices were set. Without it, the burden of proof can shift against the group, and an adjustment becomes far harder to resist.
Pricing set without a benchmark
Charges between related entities that were never tested against what independent parties would agree can be challenged years later — and the adjustment can apply to several open years at once, not just the current one.
One country adjusts, another refuses to match
When one tax authority increases your profit, the counterparty country does not automatically reduce its own claim. Resolving the resulting double taxation requires a specific procedure that few groups know how to initiate.
What you get
A transfer pricing lawyer who builds the position before it is challenged
We match you with lawyers who handle transfer pricing documentation, advance arrangements and disputes regularly across Europe.
Documentation that stands up
Your lawyer ensures the pricing of intercompany transactions is supported by proper documentation and a defensible method, so the position holds if the authority ever examines it.
Benchmarked pricing
The rates and terms applied between your entities are tested against market benchmarks, reducing the risk of an adjustment and the scope of any challenge.
Advance arrangements
Where an advance pricing agreement or similar arrangement is available, your lawyer pursues it and negotiates the terms, locking in the treatment before any dispute can arise rather than trying to fix it afterwards.
Defence and dispute resolution
If an adjustment is proposed, your lawyer responds, negotiates with the authority, and uses the available procedures to eliminate double taxation across the countries involved.
Coverage
Transfer pricing lawyers across Europe
Transfer pricing rules are largely aligned across Europe but applied nationally, and disputes span borders, so the right lawyer is one who works across the countries where your group operates. We match cases across the following countries and beyond:
Frequently asked
Transfer pricing — common questions
What is transfer pricing?
Transfer pricing is the set of rules governing the prices charged between related companies in the same group for goods, services, financing and intellectual property. Because those prices determine where profit is taxed, authorities require them to reflect the arm’s length principle — the terms independent parties would have agreed.
Does transfer pricing only affect large multinationals?
Not only. Although the most complex rules target large groups, small and medium businesses with cross-border related-party transactions can also be caught, and many countries set documentation thresholds that are lower than business owners expect. Any intercompany transaction can draw scrutiny.
What happens if the tax authority challenges my transfer pricing?
The authority may propose an adjustment that increases your taxable profit in its country. If the counterparty country does not make a matching reduction, you can face double taxation on the same profit. Resolving this typically requires negotiation and, where available, a mutual agreement procedure between the countries involved.
What documentation do I need to keep?
Requirements vary by country, but most expect records showing how intercompany prices were set and why they meet the arm’s length standard, often including a benchmarking analysis. Keeping this documentation contemporaneously — at the time the prices are set — is far stronger than reconstructing it after a challenge.
Can I get certainty in advance of a dispute?
In several countries, yes — through an advance pricing agreement or similar arrangement, where you agree the pricing method with the authority in advance. This can lock in the treatment for future years and is one of the most effective ways to avoid disputes altogether.
How is double taxation resolved between countries?
Where two countries tax the same profit, relief is often available through a mutual agreement procedure or, where applicable, an arbitration mechanism under a tax treaty. These are formal processes with their own rules and deadlines, and they are typically initiated by a specialist adviser.
Free case review
Get your transfer pricing position built before it is challenged
Tell us about your group’s cross-border transactions and we’ll connect you with a transfer pricing lawyer in your region — free of charge, with no obligation to hire.