CEO Integral Solutions

our services

transfer pricing nowadays is not just a matter of compliance.  in the world of beps, tax authorities are seeking for transparency, substance, and coherence.   our solutions will provide you a value-add according to your company's situation.  

planning / consulting

all of our services take into consideration the fast-evolving world of beps and transfer pricing.  we provide transfer pricing advice in connection with:


  • business restructurings, including advice on supply chain
  • special circumstances (e.g., start-ups, loss positions, mergers, acquisitions)
  • transfer pricing policies, intercompany entries, intercompany agreements
  • benchmarking analyses

our value


tax authorities have agreed to share information about the taxpayer.  we can provide you with:


  • a global "big picture"  of the country-by-country reporting, risk identification and advice
  • the preparation and consulting regarding country-by-country reporting, master file, and local file
  • updates regarding the evolution of beps and its implementation in your company's jurisdictions
dispute resolution

is the tax authority questioning your company's  transfer pricing issues? you are not alone! 


  • advance pricing agreements
  • transfer pricing support for audits performed by tax authorities

our services range from conducting basic searches for comparable companies ("comp searches") for benchmarking purposes to complex transfer pricing issues (e.g., ip migration, dispute resolution, restructuring, start-ups, etc.)

U.S. transfer pricing 

our services include the preparation of U.S. transfer pricing documentation as provisioned in §§ 482 and 1.6662-6 of the U.S. Treasury Regulations:


  • "principal documents" as stated in § 1.6662-6(d)
  • intercompany transfer of tangible property (e.g., distribution, retail)
  • intercompany services (e.g., management, procurement,  financial, engineering, etc.)
  • intercompany transfer of intangible property (e.g. royalty payments, cost sharing agreements)
global documentation (OECD guidelines)

we prepare global documentation for North America, Latin America, Europe, Middle East and Africa, and Asia Pacific:


  • global documentation- OECD "global" report
  • local documentation, departing from a global report, based on the OECD transfer pricing guidelines
  • local documentation focused on specific local requirements (i.e., not departing from an OECD global report)
ip migration issues

whether your company's intangible assets consist of software, know-how, pharmaceuticals,  or a non-routine intangible, we can help:


  • advice on ip migration mechanisms (e.g., ip purchasing, licensing, cost sharing)
  • financial modelling (e.g., application of the income method, residual profit splits, etc.)
  • consulting regarding cost sharing agreements

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