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Transfer Pricing

With globalization, cross-border transactions and complex national and international regulations, our lawyers help clients to limit their related tax risks and take advantage of planning opportunities. 

Companies recognize the value of proactively managing transfer pricing. Get it right and the benefits can be substantial. Get it wrong and the consequences may be devastating, including financial and reputational damage. A growing number of African countries are introducing comprehensive transfer pricing legislation and many tax administrations have developed or are developing specific transfer pricing expertise. 

This has led to additional compliance obligations and uncertainty for companies in this region. We work with multinational clients across Africa, and our lawyers, economists and certified tax advisors provide a full range of tax advisory services. Moreover, thanks to our global platform, you can work with a single advisor across multiple jurisdictions. 

Local insight, global reach: operating in 20 African countries, we understand the political, financial, regulatory and economic issues in the region, and have worked extensively with policymakers and tax officials in Africa on implementing transfer pricing rules. We bring in-depth knowledge of the transfer pricing issues that clients typically face in Africa and how to manage and prepare for them. 

Our global Africa team comprises more than 200 lawyers in Johannesburg, Casablanca, London, New York, Paris, Dubai, Perth, Hong Kong and Beijing. We also draw on the multidisciplinary resources of one of the world’s biggest business law firms, providing consistent advice and support − so you can develop and implement a robust transfer pricing policy, then support and defend the policy wherever you need to. 

Key capabilities include: 

  • strategic advisory: planning and structuring, transfer pricing policy design, risk assessment, documentation review and advice
  • transfer pricing compliance: strategic evidence-based transfer pricing documentation tailored to meet specific requirements and approach of local authorities
  • legal agreements: leveraging our legal network to review and draft intercompany agreements consistent with the applicable transfer pricing policy
  • dispute resolution: audit support, litigation support and assistance mutual agreement procedures
  • Advance Pricing Agreements (APA): prefiling meetings, application, negotiation and renewal, assisting governments to establish processes and procedures where an APA program is not in place, providing opportunities to pursue an APA where one was not previously possible
  • transfer pricing and customs valuation: planning, dispute avoidance and resolution 

Please contact us to discuss how we can help you to achieve your objectives.