Industry specialization
Focused on the unique economics of banking and capital markets—such as funding, liquidity, risk transfer and regulatory capital—designing policies that align intra‑group pricing with treasury, trading, lending and advisory functions. We combine deep knowledge of regulatory and BEPS-driven expectations with quantitative modelling (e.g., for risk and intangibles) to help institutions withstand scrutiny from both tax and financial regulators across multiple jurisdictions.
Financial Services
Tailored services to the specific value chain of fund sponsors, managers, advisors and distribution platforms, with particular attention to profit allocations between front‑office portfolio management, investor relations, and back‑office operations. Our services address nuanced topics such as management and performance fee allocation, IP and strategy development, substance in management companies, shareholder loans, M&A structuring (particularly for Private Equity investments) and the treatment of carried interest and co‑investment structures.
Asset Management
Focused on end‑to‑end value chain and supply chain transfer pricing—covering sourcing, manufacturing, logistics, distribution and after‑sales services—so that profits align with actual economic contribution in each jurisdiction. Our services include business restructurings (e.g., conversion to principal or limited‑risk models), addressing IP and brand ownership, and designing resilient pricing frameworks that can handle volatility in raw material costs, freight, and inventory risk.
Products (Consumer and Industrial / Retail and Manufacturing)
Centered on the complex valuation and remuneration of intangibles—software, platforms, data, algorithms, content, and brands—as well as the allocation of profits in digital and subscription‑based business models. Our services help clients navigate issues like DEMPE analysis, integrated R&D and engineering centers, global licensing and cost‑sharing arrangements, cloud and SaaS remuneration, and the interaction of transfer pricing with evolving digital tax rules.
TMT (Technology, Media and Telecommunications)
Emphasizing the pricing of R&D, clinical development, regulatory approval, and commercialization activities for pharmaceuticals, medical devices, and healthcare services. Our services address nuanced matters such as allocation of returns to patents and clinical know‑how, cost‑sharing and contract R&D structures, regional commercialization and distribution models, and the alignment of transfer pricing with strict industry regulation, pricing controls and government payor environments.
Healthcare and Life Sciences
