Our Solutions

Innovative thinking across the TP Lifecycle

TP Lifecycle

Questro International is a specialist firm which provides a full range of transfer pricing solutions across the entire Transfer Pricing Lifecycle for a broad spectrum of transfer pricing projects. We combine classical transfer pricing advisory work with innovative IT solutions to create value and efficiencies for our clients.

All of our Solutions are implemented with a clear Transfer Pricing Lifecycle perspective. The TP Lifecycle characterises where a project fits along a timeline from initial design work, through documentation and control efforts, to the inevitable interaction with tax authorities via upfront agreements, or subsequent enquiry management and conflict resolution.

Cost Effective & Flexible

Questro International is able to offer clients both individual and multi-phase projects across the entire TP Lifecycle. We believe in long-term client relationships and, for us, this means establishing projects that are both cost effective and flexible over a multi-year TP Lifecycle.


During the Design Phase, Questro helps clients to:


During the Document Phase, Questro helps clients to:


During the Control Phase, Questro helps clients to:


During the Defend Phase, Questro helps clients to:

Identify TP relevant transactions

Consider transactions in terms of functions undertaken, risks assumed, and assets employed

Address alignment of the TP Model with your broader Business Model

Quantify tax risks and opportunities

Design new or updated TP arrangements

Advise on documentation strategies, policies, or processes

Prepare supporting compliance documentation cost effectively

Undertake economic analysis to set or support the pricing model

Determine the arm's length borrowing capacity and interest rates for financing transactions

Draft TP operating guidelines for your business

Establish clear TP policy documentation (incl. governance processes)

Identify risks of process failure and recommend changes

Update you on changes of law or practice in foreign jurisdictions

Adjust TP models quickly to address business or macroeconomic changes

Implement appropriate TP processes and controls in line with your Tax Control Framework

Improve internal TP competences via training, workshops, or other learning offerings

Manage TP enquiries for local tax authorities and respond on your behalf

Advise on defence strategies

Negotiate with tax authorities

Prepare defence documentation for TP systems under challenge

Issue opinion letters to help you understand the risks and likely outcomes

Secure advance clearances or pricing agreements from tax authorities (ruling or APA)

Handle Competent Authority claims

Resolve controversy with tax authorities and, if necessary, advise on litigation

TP Framework

We are often asked by clients what elements are required to make a great TP framework? Whilst the answer will always depend on the underlying fact pattern of the client, their overall tax policy and appetite for risk, the following points should be considered: