Expert transfer pricing solutions

Nord Advisory is an independent provider of expert transfer pricing advisory, compliance and technology solutions. We provide the highest quality expertise to our clients and have a primary focus on the Scandinavian region.

We are a member of the Quantera Global Network, an international network of specialized transfer pricing firms with locations in over 40 countries

Design & Optimize TP Models Click here to read more
Price Financial Transactions Click here to read more
Develop Profit Split Models Click here to read more
Value Intangible Property Click here to read more
Benchmark Profit Levels & Royalties Click here to read more
Prepare, Update & Review Documentation Click here to read more
Implement & Operationalize TP Models Click here to read more
Engage Experts Click here to read more

Design & Optimize TP Models

A well-designed transfer pricing model helps optimize your tax position and reduce exposure to potential adjustments and penalties. We tailor transfer pricing models to align operational and tax consequences considering:

• Central Entrepreneur Modeling Selection and application of proven and efficient transfer pricing structures across diverse industry sectors.
• Intragroup Services Analysis and modeling of management cross-charges; including description of services, benefit test analysis, cost allocation methodology and determination of arm’s length mark-up.
• Cost Contribution Arrangements (CCAs) Design and implementation of Cost Contribution Arrangements with particular consideration to BEPS Action 8 guidance.

Price Financial Transactions

Intercompany financial transactions are increasingly challenged by tax authorities. We price and defend multiple types of financial transactions:

• Intercompany Loans Defensible arm’s length pricing analysis scalable to all loan types, sizes and risk coverage needs.
• Cash Pools Defensible arm’s length pricing analysis of cash pool arrangements, both notional and zero-balancing.
• Intercompany Guarantees Multiple analytical methods to price and benchmark guarantees; including upstream, downstream and cross-guarantees.
• Defense & Litigation Manage debt pricing defense and litigation proceedings.

Develop Profit Split Models

Profit split analyses are more common and complex as multinationals increasingly utilize intangible assets, integrate businesses and share economically significant risks amongst intra-group entities. We develop profit split models using:

• Contribution & Residual Analysis Selection of appropriate analytical approach to ensure technical accuracy and defensibility.
• Functional Analysis Managed functional interview process based on stakeholder inputs.
• Supporting Valuations & Benchmarks Relevant and accurate valuations and benchmarks that support profit split models.
• Implementation Software solutions, clearly written policy documents and other means that implement a profit split model in a pragmatic and user-friendly way.

Value Intangible Property

The valuation of intangible assets as a material source of profit, particularly in a post-BEPS transfer pricing environment, is a key consideration. We produce robust and defensible valuations using:

• Analytical Approaches Multiple methods for comprehensive analysis: market, income, and cost approaches.
• Benchmarking Industry-standard databases, with relevant licensing agreements for use in benchmarking, via the market and income approaches.
• Best Practices Insights from prior audits, transfer pricing analyses, mergers & acquisitions and business reorganization.

Benchmark Profit Levels & Royalties

Benchmarks are an essential element of transfer pricing models for setting and validating prices and margins. We create defensible and tailored benchmarking studies including:

• Transaction Net Margin Method (TNMM) Detail-oriented and thorough TNMM benchmarks within various industry segments and geographies (Pan-European, North American and Pan-Asian).
• Royalty Benchmarks Benchmarking the arm’s length royalty rates of unique IP assets, particularly relating to trademarks, tradenames and know-how across diverse industry sectors.
• Comparability Adjustments Adjustments to the comparable data or the data of the tested transaction that improve the comparability of the benchmark.
• Databases Use of industry-standard databases for benchmarking of profit levels, prices and royalties.

Prepare, Update & Review Documentation

Tax authorities start with your transfer pricing documentation, having clearly structured, up-to-date documentation is essential. We deliver documentation, with particular emphasis on:

• BEPS-compliance BEPS Action 13 transfer pricing documentation packages including the BEPS-defined Master file and Local file.
• Country-by-Country Reporting (CbCR) Country-by-Country Reporting including determination of reporting requirements, data collection, report creation and final review.
• Country-specific Documentation An international network of affiliates to deliver transfer pricing documentation tailored to a client’s domestic documentation requirements.
• Scandinavian Documentation Nordic staff to prepare, update and review transfer pricing documentation reports for entities located in Norway, Denmark, Sweden and Finland.
• Compliance Review Knowledge of tax authorities requirements to review documentation produced internally or by other external advisors.

Implement & Operationalize TP Models

Reduce time burden, tax risk and increase transparency and accuracy by operationalizing the testing of your intercompany transactions, calculation of margins and determination of adjustments. We assist in all phases:

• Design Policies Translation of TP models into practical policies for everyday application.
• Monitor & Review Software solutions for the monitoring and review of TP policies.
• Integrate Statutory Accounts Integration of local transfer pricing reports and CbCR with statutory accounts.

Engage Experts

Judicious use of subject matter experts enhances the defensibility of TP cases. When needed, we provide such experts for general consultation, and for the following specific cases:

• Expert Testimony Leverage Nord’s extensive audit and litigation experience, particularly relating to the transfer pricing of financial transactions. In addition to in-house experts, Nord uses affiliates whose expertise span multiple regulatory jurisdictions and industries.
• APAs & MAPs Negotiation of advanced pricing agreements and mutual agreement procedures with tax authorities.
• Request for Proposal (RfP) Solicitation of outside resources to manage the RfP process, including: RfP preparation, review of received proposals and recommendations based on industry insight.
• Second Opinion & Assurance Get a second opinion of transfer pricing work performed internally or by external consultants.
• Due Diligence Perform due diligence on transfer pricing aspects of a merger, acquisition or initial public offering.

Raising the bar in transfer pricing

Nord was founded with the purpose of addressing the need for both subject-matter expertise and technology solutions in the increasingly sophisticated area of transfer pricing. Nord utilizes its experts’ backgrounds in transfer pricing, tax and finance to deliver industry leading solutions.

We take pride in the quality of our work and we focus on client satisfaction. We are happy to travel to work onsite with you to deliver the best solution for your transfer pricing needs.

Michael Rasmussen

Principal

Michael has over 27 years of experience working in the tax function of Norwegian companies, Big-4 consultancy and the Norwegian Tax Authority. His most recent position was Tax Director of the former Norwegian publicly listed company Eltek ASA. Read more

Contact Michael LinkedIn

Nord Advisory AS

MESH | Tordenskiolds gate 2, Oslo 0160, Norway

+47 900 56 490

rasmussen@nordadvisory.com