Classic TP Solutions

Questro provides a full range of Classic Transfer Pricing Solutions across the entire Transfer Pricing Lifecycle, which are well understood by our clients and offered at attractive fee rates and/or on a fixed fee basis.We combine classical transfer pricing advisory work with industry specific expertise to create value and efficiencies for our clients. In this respect, we have worked on a broad spectrum of different transfer pricing projects. Below, we highlight the importance of a "total lifecycle costs" approach, and list typical projects areas, before providing a matrix summarising additional subject matter expertise.

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How Questro helps clients

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Recommended approach

An avalanche of new TP compliance requirements, together with increased transparency and scrutiny from a wide range of stakeholders, makes the operation of a sustainable TP model more complex and increasingly cross functional within a corporation. In this context, it is necessary for multinationals to fully assess their TP environment so as to efficiently manage risks and seize opportunities.

Multinational corporations are increasingly looking at the total lifecycle costs of any TP model. Corporate social responsibility and brand protection issues should now be part of this calculation. Implementing and documenting a robust TP model that balances tax risks & opportunities with strong TP governance processes will help your organisation build trust and avoid unnecessary disputes or erosion of brand reputation.

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Global TP Documentation

Many jurisdictions have now adopted the OECD's recommended TP documentation approach as stated by the OECD in its final BEPS report (Action Item 13). This three tiered documentation approach, consists of: (i) a Master File containing standardised information relevant for all MNE group members; (ii) a Local File referring specifically to the functional profile and material transactions of the local taxpayer; and (iii) a Country-by-Country Report covering the global allocation of the MNE’s income (only for MNE groups with consolidated group revenues of more than EUR 750m). We can help you to find efficient ways of managing you approach to the preparation and maintenance of Global TP Documentation.

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Cash Pools

Centralised management of excess liquidity is becoming increasingly important for Multinationals to decrease group funding costs. Also, operating companies should not have to allocate resources and maintain expertise in the area of funding. Typical transfer pricing challenges with cash pooling are that: independent parties do not engage in cash pools, thus, no transaction specific third-party comparables exist; neither the OECD’s Transfer Pricing Guidelines, nor local country guidelines across European jurisdictions, provide much useful guidance; and case law is very limited in this area and difficult to use. We have significant experience in this area.

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Central Entrepreneur Models

Regional or global centralised business structures are increasingly common and are attractive if you can ensure the principal company possess the appropriate competences to manage the business and related risks. If such centralised business management can be implemented from an operational perspective, a number of cost savings can typically be achieved, and there are several tax optimal transfer pricing options available.

IP Assets


If marketing intangibles, (trade names, trademarks, or product brands), are licensed (or used) within a group, a royalty should be paid by the licensee (or user). Questro are regularly involved in the design, benchmarking, and documentation of branding fees models across many industries.

Trade intangibles

Patents, know-how or other trade intangibles that are owned by one group entity and are licensed (or used) by others should also be subject to arm’s length royalties. Whilst charging for marketing IP is very common, many companies fail to fully charge for their technical IP.

Project Expertise

Our independence and size makes us attractive for highly confidential or sensitive engagements (e.g., family office work, controversy, risk reviews, IP planning, M&A work, 2nd opinion work, expert witness reports etc.). In addition, we have significant experience in the following:


Finance Companies

We have extensive experience in determining the net or gross margin for intermediate finance companies and can support you in preparing compliance documentation.


Questro International has been involved in projects for multinational groups that are exposed to a significant level of third-party receivables that are traded intra-group.


Financial guarantees are commonly used by multinationals, from single guarantees to more complex arrangements, but they require careful pricing, which we can support.

Manufacturing Models

Establishing (or converting to) a contract or toll manufacturing can offer attractive tax savings, but experience in supply chain projects is essential. We have worked in this area for many years.

Mergers & Acquisitions

In case of acquisitions, a transfer pricing due diligence should be performed whereby the transfer pricing risks of the target group are mapped to avoid costly issues later. We work closely with several Law Firms in this regard.


For multinational groups operating in R&D intensive industries, the location and legal structuring of R&D activities often drives the TP model. We support clients with R&D structuring and the related IP DEMPE issues.

Re-invoicing Companies

Corporates may set up re-invoicing companies to simplify the re-invoicing of support services (i.e., clearing houses) and we can assist you with setting pricing policies for such clearing houses.

Sales Models

Most companies require a fixed sales structure where their customers are located. Questro can explore with you a variety of sales models that fit your operating model within a tax-optimised framework.

Service Models

Many different models exist for remuneration of services. Questro can advise on simple cost reimbursement, mark-ups on costs or expenses, or complex value based service fees models.

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