Transfer pricing strategy and policy design

Transfer pricing policies should reflect how the business actually creates value. We help multinational groups design and implement policies that are technically robust, commercially understandable and workable for finance teams, business stakeholders and tax authorities. 

Why this matters

A policy that looks correct on paper can still create risk if it is not aligned with the operating model, not supported by data or not consistently applied across entities. Belgian and foreign tax authorities increasingly test whether intercompany pricing follows the substance of the business, whether methods are applied consistently and whether year-end outcomes are in line with the arm's length principle.

How we help

• Map the operating model: identify material intercompany flows, key value drivers, decision-making processes and the entities housing significant people functions.
• Define the transfer pricing policy: select methods, tested parties, profit level indicators, pricing mechanisms, allocation keys and target outcomes.
• Align policy with value creation: connect functional analysis, value chain analysis and DEMPE analysis with the proposed remuneration model.
• Support implementation: translate the policy into practical instructions for finance, legal and business teams, including pricing calendars and true-up mechanics.
• Prepare audit-defensible evidence: document the commercial rationale, method selection, comparability assumptions and implementation logic.

Typical deliverables

• Transfer pricing policy document or policy manual
• Transaction mapping and materiality assessment
• Functional analysis and value chain analysis
• Method selection analysis and pricing model
• Implementation roadmap and governance recommendations
• Support with finance team instructions and intercompany charging processes

Typical triggers

• New Belgian or international transfer pricing legislation or documentation requirements
• Changes to the group’s operating model, value chain or supply chain
• Implementation of new business strategies, commercial models or transaction flows
• Expansion into new jurisdictions, markets or business lines
• Material changes in margins, transaction volumes or intercompany flows
• Need for a consistent group-wide transfer pricing policy or harmonised pricing model
• Finance or ERP implementation affecting intercompany charging
• Internal or external audit questions, tax authority enquiries or need for increased tax certainty