About
TPGS Group (“TPGS”) is an innovative consulting firm focused on transfer pricing. TPGS is an independent company providing international transfer pricing services to international groups and professional service providers like law firms, trust companies, and auditors, to resolve the transfer pricing needs of their clients.
We are headquartered in Italy (Genova) and Luxemburg where we have operations.
20+
Thanks to our international network we operate in more than 20 countries around the world.
" The extraordinary success of TPGS has meant that it is the ‘resident partner’ within a number of multinational groups operating across several industries, from shipping, to trading of commodities, luxury goods, technology and investment funds. "
— Cristiano Bortolotti, CEO TGPS
TPGS Group
TPGS was established in 2015 to meet increasing demand for transfer pricing services.
TPGS has been established by Dr. Cristiano Bortolotti who matured 15 years’ experience in tax, finance and legal departments of very large multinational enterprises of different industries. Cristiano moreover, since 2014 is teacher and scientific collaborator at the University Supsi in Lugano, Switzerland. He regularly publishes articles on the university scientific magazine and speaks at seminars.
Cristiano finally matured a unique experience as equity partner of Dentons, the largest law firm on Earth, as economist and legal advisor in transfer pricing matters.
TPGS resolves transfer pricing issues for:
Law firms, trust companies or auditors
Law firms, trust companies or auditors who advise multinational enterprises but do not have a transfer pricing department.
Multinational enterprises (MNEs)
Multinational enterprises (MNEs) who do not have in-house transfer pricing expertise.
Collaborations
TPGS regularly collaborates with prominent independent law firms throughout Europe. It also collaborates closely with universities and take pride in the fact that it assists young professionals who wish to have a career in international transfer pricing.
TPGS aims to improve constantly its operations in Switzerland and Luxembourg and to streghten its presence in the key European jurisdictions by representative desks starting from 2020.
Vision
Two different approaches to TP consulting, tailor-made for clients
Multinational enterprises (MNEs)
TPGS believes that transfer pricing assistance should not be provided on a once-off basis. Instead, risks related to transfer pricing must be managed continuously, developing in the context of the specific business needs of the company. Transfer pricing policies must be robust in order to withstand challenges from tax authorities; the risk of such a potential challenge must be considered when evaluating the suitability of adopting the TP policy.
It is imperative that TP policy is not developed unilaterally by a finance team without the involvement of other departments in an organisation. Key stakeholders should participate in the identification of any relevant issues and the development of the functional, asset and risk profile of the organisation. It is also important that the legal, tax and accounting teams develop a close working relationship in order to most effectively implement TP policy.
Professional advisory firms
Where professional service firms do not have internal TP expertise, TPGS provides assistance in the resolution of their clients’ TP issues. This allows firms to provide a wider suite of services to their clients.
Professional advisors have a deep understanding of their clients’ business and corporate needs; this knowledge can be incorporated into the transfer pricing process.
Independency
TPGS is an independent company that works with MNEs and their advisors without encountering conflicts of interest. This makes TPGS a unique player in the market.
Multidisciplinary approach
Transfer pricing is a very peculiar practice because it is the combined result of economic science, legal practice, applied on an ultra-national scale. Transfer pricing is the sum of three different practices.
Continuity of the service
Transfer pricing services cannot be provided on a once off basis. TP policies must be maintained, reviewed and managed continuously. Efficient continuity of services is offered at competitive prices.
Efficiency
TPGS offers reasonably priced service when compared with competitors’ service offerings thanks to its straight forward organisation.
Quality
TPGS has access to the best in class databases, the same commonly accepted and used by tax administrations worldwide.
Flexibility
TPGS’ organisational structure allows it to be flexible, enabling it to react quickly to clients’ needs.
TPGS Services
- Review the legal ownership and geographical location of operations.
- Determine the drivers of profit, understand current markets,
- Review I/C arrangements
- functional analysis.
- Risk analysis
- Asset analysis
- Value chain analysis
- IP analysis: DEMPE functional analysis and market evaluation
- To define and describe the controlled transaction
- Select the most appropriate TP method.
- Select appropriate comparables.
- Apply the results of the benchmarking and economic analysis to the facts of the relevant case.
- Update the report incorporating the items referred to above.
- Share the results with the client.
- Analyse group TP policies, documentation and assessment from tax inspectors.
- Assist the legal/tax team to analyse the output of the assessment and define the defence strategies, if necessary.
- Analyse the strengths and weaknesses of the assumptions made by Revenue in determining the quantum of tax owed.
- Prepare a reply to Revenue.
- Follow up and assist the tax/legal team during the different phases of the litigation.
- Assitance during the tax audit and participation to meetings
- Value chain analysis, current TP policies and supporting documentation.
- To document compliance with TP policies.
- To analyse the risks related to the TP policies of the business and determine if there is consistency with the buyer’s existing TP policies.
- Provide input into the indemnities and warranties to be included in SPA.
- Analyse the restructuring proposal.
- Analyse existing TP documentation and determine if it is in compliance with OECD standards, local regulatory standards etc.
- Consider how the restructuring proposal impacts on the value chain, functions and risks of the group.
- Determine whether or not the TP policies and documentation adopted before the restructuring are still relevant.
- Apply the TP business restructuring rules.
- Define new TP policies and documentation if necessary.
- Share the results with the client.
- Analyse group TP policies and documentation.
- Draft APA to include outline of business model and economic studies.
- Discussion with relevant competent authority.
- Annual review of client performance in relation to the APA.
- Collect of information regarding the amount of revenue, profits, taxes and other indicators of economic activities for each tax jurisdiction in which the MNE group does business.
- Assess the information collected and incorporate into the CBC Report
- As a consequence of the above, assess TP risks and other BEPS related risks
- Complete overview of the MNE group: global operations, TP policies, allocation of income and economic activity
- Review the organisational structure and geographical location of entities, business activities, financial activities, intangibles and tax position
- Briefly describe the principal risks influencing the business and functions contributing to the value chain, i.e. key functions performed, risks assumed and assets used
- Document the important restructuring transactions, acquisitions and divestitures during the fiscal year
- Describe the overall strategy for intangibles, including location of principal R&D facilities and management, and description of important transfers of interests in intangibles to Associated Enterprises
- Provide overview of group finance, identify the central financing functions within the MNE group and complete overview of TP policies between associated enterprises
- Review the MNE’s annual consolidated financial statement and briefly describe the existing unilateral APAs relating to income allocation amongst countries
- Summarise all the above and identify potential risks and make appropriate adjustments
- Analyse existing TP documentation.
- Ensure that existing TP policy is in compliance with OECD standards on controlled transactions, confirm consistency with financial data and consider if I/C agreements are in compliance with TP documentation.
- In circumstances where a different methodology or comparable is to be implemented, quantify the financial impact of the change.
Contact
Via Innocenzo Frugoni 15/7 - 16121 Genova (Italy)
12 Rue G. Schneider - L2522 Luxembourg
Contact us for more informations.
Our administration office will be happy to contact you about advanced inquiries and to address you to our expert office: