Intercompany transactions are at the heart of how multinational groups create, price, and share value across borders. When transfer pricing rules tighten and documentation expectations rise, you need an advisor who understands both the technical rules and the commercial reality of your business. At KNAV, the focus is on building transfer pricing solutions that are tax-efficient, defensible, and aligned with your global operating model.
Transfer pricing that matches your business
Intercompany transactions can range from tangible goods and routine services to complex financing, intellectual property, and digital business models. KNAV’s International Tax and Transfer Pricing team designs and reviews pricing policies across this full spectrum so that margins, royalties, and fees reflect where functions, assets, and risks truly sit. This helps you manage effective tax rates, avoid double taxation, and support consistent results across jurisdictions.
Transfer pricing is approached as a strategic discipline, not just a compliance exercise. That means starting with a clear understanding of your value chain, legal structure, and commercial drivers, then translating this into policies and documentation that your tax teams, auditors, and local tax authorities can all rely on.
End-to-end transfer pricing lifecycle support
Your business needs more than a one-time study. KNAV supports the entire lifecycle of your intercompany arrangements—from initial design and implementation through monitoring, defence, and periodic refresh. Typical support includes:
- Designing and revising transfer pricing policies for goods, services, IP, financing, and cost-sharing arrangements.
- Preparing master file, local file, and country-by-country reporting outputs that are aligned with BEPS requirements and local rules.
- Conducting risk assessments and “health checks” on existing transfer pricing models, highlighting exposures before they surface in an audit.
- Assisting with transfer pricing integration following mergers, acquisitions, business reorganizations, and market expansions.
This holistic view ensures your policies, contracts, actual conduct, and financial outcomes remain aligned over time, even as your business changes.
Robust documentation and benchmarking
High-quality transfer pricing documentation is your first line of defence against tax adjustments and penalties. We prepare tailored documentation that explains your business model, performs functional and risk analyses, and supports margins with robust benchmarking. Comparable searches use globally accepted databases and methodologies, with clear rationales and audit-ready files.
Annual updates keep your benchmarking and economic analysis current, so you are not relying on stale comparables or outdated assumptions. For groups that run some of this work in-house, KNAV can step in for specific pieces, such as database searches, segmentation of financial data, or review of draft reports, to strengthen positions before filing.
Planning, controversy, and dispute resolution
When tax authorities challenge intercompany pricing, the priority is to protect value while minimizing disruption. KNAV helps you prepare for and manage audits, responding to information requests with consistent, evidence-based narratives supported by your documentation and commercial facts. Where appropriate, the firm advises on advance pricing agreements (APAs), mutual agreement procedures (MAP), and other dispute‑resolution tools designed to eliminate or reduce double taxation.
On the planning side, KNAV works with leadership teams on cross-border structuring, business model changes, and supply chain realignments, always considering transfer pricing, international tax rules, and treaty networks together. The goal is to move beyond point solutions and build global models that withstand regulatory change and sustained scrutiny.
A strategic partner for global groups
Intercompany transactions may be complex, but they do not have to be a constant source of uncertainty. With KNAV, you gain a partner who understands the pressure from regulators, investors, and boards for transparent, well-governed transfer pricing. The team helps you turn technical rules into clear, actionable policies, backed by rigorous analysis and practical experience across multiple industries and corridors.
If you are looking to optimize tax efficiency, reduce the risk of transfer pricing adjustments and penalties, and bring confidence to your intercompany framework, KNAV’s International Tax and Transfer Pricing practice is ready to help.
