OECD BEPS-aligned transfer pricing, DTAA optimisation, PE risk and Pillar 2 (15% GMT) impact modelling.
Transfer pricing adjustments are the #1 cross-border tax exposure for scaling startups — and Pillar 2 (15% global minimum tax) now applies to groups >€750M. Without a master file, local file and CbCR, an Indian or US tax notice can freeze cash for 18+ months.
A senior-led delivery sequence — not a template dump. Each phase is operated with your team and external counsel, not handed over as a deck.
Map every intercompany flow — services, royalty, loans, cost-sharing — across the group; classify each against OECD BEPS guidelines.
Run the FAR (Functions, Assets, Risks) analysis per entity with operations and finance leads to anchor the transfer-pricing posture.
Comparable-company benchmarking using accepted databases, set arm's-length ranges, author the group transfer-pricing policy and intercompany agreements.
Optimise treaty selection (DTAA + LOB clauses), assess PE / DAPE / SEP risk per geography and design mitigations with international tax counsel.
Model the 15% Global Minimum Tax (GloBE) impact, ETR per jurisdiction and top-up tax exposure; design GIR / IIR / UTPR readiness.
Master-file + local-file + CbCR documentation finalised, signed off by tier-1 audit partner and embedded into the year-end close.
10–16 weeks initial; annual refresh cadence