Our services cover all aspects of the advisory and compliance TP business lifecycle.

Methodology

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  • Whether long-standing international structures exist or the group is new to international business, there can be TP design needs.

    We have extensive practical experience in design and implementation of TP policies and operating models, arising from material factual, market or economic change.

    Groups need to be confident that their structures are robust and generate results which satisfy the arm’s length principle, whether under OECD, US §482 or UN guidance.

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  • Changes in operating models require practical, hands on, operational support.

    In our experience, a lack of operational TP support can let down the very best theoretical model.

    In contrast, real-time implementation and ongoing monitoring will facilitate consistent arm’s length pricing.

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  • We have practical experience of dealing with authorities globally, assisting with the following type of requirements:

    • Detailed documentation support under scrutiny

    • Managing TP communications with tax authorities

    • MAP procedures to seek tax symmetry

  • Country-specific requirements have increased exponentially over recent years. In practice, the more traditional TP documentation needs are wider than may be expected. Our work often includes:

    • TP risk reviews, covering global operations

    • TP policy recommendations

    • Benchmarking comparable data

    • TP Master files and Local files

    • Formal legal agreement review

    • Thin capitalisation

    Our approach to documentation is bespoke, rather than “one size fits all”.

Sector Understanding & Expertise

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Large or small MNEs requiring TP advisory work, project implementation, dispute resolution or compliance support.

MNEs

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Professional Firms who do not have dedicated TP resources in-house - we can stand behind you, or shoulder to shoulder with you, on client projects.

Accountants & Lawyers

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Groups needing to bridge between in-house TP appointments, either on a short or longer term secondment basis – keeping the work flowing whilst you find your ideal candidate.

Bridging the Gap

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Our Core Values

At Abaris, we make certain that we deliver practicality and excellence in everything that we do.

With us, you can be certain that you will receive Director-led service, with the guaranteed assurance of advice personally delivered by one of our Directors.

Your business will benefit from the wisdom and insight of our Big 4 pedigrees, combined with the practical, hands on experience that comes from our years spent implementing TP in industry.

High Praise

  • "I’ve been impressed with the hands-on approach of Abaris. They took a real interest in our business and worked closely with us to produce a tailored solution."

    Head of Tax & Corporate Structuring, FTSE 100 MNE

  • "Erica and Chloë are very personable experts. They provided a solution that matched our needs and was easy to understand. They did not drown me in jargon and made a dry subject almost pleasurable."

    Finance Director, London headquartered law Firm

  • "I cannot fault the service that you have provided. It has been very professional throughout, with clear goals and excellent communication."

    UK Finance Director, German Listed Group