CREDENTIALS
Representative engagements across transfer pricing policy, litigation support and data-driven economic analysis.
TP qube applied the internal CUP method to update the transfer pricing policy between French and US entities of a listed medical device company. The analysis combined third-party transaction review, comparability adjustments, econometric modelling of volume discounts and customs-fee allocation.
TP qube developed a tailored patent royalty analysis for a leader in the packaging industry where a simple external CUP was not appropriate. The work combined management and R&D interviews, ERP data analysis and economic modelling to measure the benefit of the patented technology.
TP qube built bespoke data pipelines to extract, clean and structure ERP data for a leading European industrial multinational. The solution embedded tax logic, review workflows and exception handling to support recurring customs and VAT outputs.
TP qube designed a transfer pricing system for a technology company operating in the US and Europe. The work included the determination of an arm’s length royalty for the relevant intangibles in the context of a change in activity.
TP qube analysed compliance to UK thin capitalization rules and estimated an arm’s length range for a loan granted by a major IT company to its UK subsidiary.
TP qube assisted a French listed medical device company in the determination of its global transfer pricing policy.
TP qube assisted a leading European food company in defining its intragroup financing policy across multiple jurisdictions. It included computations for all arm's length interest rates for intragroup credit facilities across Europe.
TP qube reviewed the IT cost allocation policy of a technology company, including ERP-related costs, to support a more robust allocation framework.
TP qube prepared worldwide TNMM/CPM benchmarks covering marketing, manufacturing and distribution activities for a global cosmetics company.
TP qube helped a large European pharmaceutical group define a compliant transfer pricing policy. The assignment included an in-depth review of management fee computations and the preparation of local file documentation.
TP qube prepared European local files for a luxury group, ensuring consistency with its transfer pricing policy and documentation requirements.
TP qube determined the transfer pricing policy for a French industrial group with distribution activities in the United States.
TP qube prepared a TNMM benchmark for rubber processing activities in Africa. The analysis applied the TPED framework to address country risk adjustments in markets with limited local comparables.
TP qube determined the transfer pricing policy for a French agritech group developing its activities in the United States.
TP qube performed internal and external CUP analyses for a US SaaS company to support the definition of its global transfer pricing policy.
TP qube combined CUP analyses and a benefit test to estimate a challenging IP royalty, with global application. The work relied on both internal and external data to support the royalty framework.
TP qube analysed the cash pooling arrangement of an Irish ecommerce company and assessed the related financial transfer pricing implications.
TP qube prepared a set of TNMM/CPM benchmarks for a global SaaS company to support its worldwide transfer pricing policy.
TP qube prepared East Asia TNMM benchmarks for a French apparel company, supporting the review of its regional transfer pricing policy.
TP qube prepared master file and local file documentation for a North American industrial group covering its American operations.
TP qube prepared TNMM benchmarks covering East Asia, the United States and Europe for a French apparel company. The work supported a consistent approach across several regions.
TP qube prepared an engineering services benchmark for a Japanese company operating in the renewables sector.
TP qube analysed intragroup loans for an asset owner active in the renewables industry and assessed the related arm’s length financing terms.
TP qube assisted tax lawyers during a tax audit involving a transfer pricing matter for a consulting firm.
TP qube assisted tax lawyers during a tax audit involving a transfer pricing matter for an Italian consumer goods company.
TP qube assisted tax lawyers during a tax audit involving a transfer pricing matter for a Spanish automotive company.
TP qube assisted tax lawyers during a tax audit involving a transfer pricing matter for a shipping company.
TP qube assisted tax lawyers during a tax audit involving a transfer pricing matter for a large French industrial company.
TP qube contributed to a TPED research paper on selecting and adjusting foreign comparables in countries with limited local data. The work included statistical modelling on country risk and profitability, supporting a practical framework for benchmarks in data-scarce geographies.
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