Transfer Pricing

Transfer Pricing documentation is becoming increasingly important to meet legal documentation requirements and to be prepared for questions from the Tax Authorities. How do you develop the documentation as efficiently as possible and how do you keep it up-to-date?

robert de vries

It’s our ambition to further optimize the process regarding compliance and litigation in all aspects of transfer pricing in most pragmatic and efficient way. Using the ideal combination of human knowledge and artificial intelligence.

Modular approach

To meet transfer pricing documentation requirements, we have developed a thorough modular approach. Ex Nihilo offers various solutions ranging from a review of documentation to identify potential risks, shortcomings, do’s and don’ts to complete outsourcing of your documentation. Our modular approach allows you to prepare parts of the documentation yourself, optional with our software tools, under the guidance of our specialists.
In any case, fully outsourced to largely insourced, we compile, update and review transfer pricing documentation not only from a compliance perspective, but also from a risk perspective. We minimize this risk by supporting companies in the preparation and implementation of a Value Chain Analysis, in which the business processes of your company are consistent with the tax rules of the various countries.
With our broad experience in Supply Chain Analysis and Value Chain Analysis we are the perfect partner in the field of Transfer Pricing documentation services.

Transfer pricing Cycle

Transfer pricing documentation is an important part of being compliant with local rules and regulations. Being fully compliant starts with defining the transfer pricing strategy and ends with the implementation of the defined transfer pricing methods and ensuring the actual results fall within the defined (interquartile) range.

Based on your current structure and processes we define and develop a strategy which strengthens the efficiency and tax control framework.

The information included in your transfer pricing documentation needs to be aligned with the (f)actual situation, realized result on intercompany transactions need to be aligned with the defined arms’ length price described in the documentation.


Intangibles are of critical significance for multinational enterprises from a business, operational and tax perspective.
Under the arm’s length principle, each member of the multinational enterprise group should receive arm’s length compensation for the functions performed, assets used, and risks assumed.

In cases involving intangibles, this includes functions related to the Development, Enhancement, Maintenance, Protection, and Exploitation of intangibles (DEMPE). DEMPE is a analysis designed to ensure that allocation of the returns from the exploitation of intangibles, and also allocation of costs related to intangibles, is at arms’ length.