Project Overview

Our defensive restructuring project was designed to help manufacturing companies facing transfer pricing challenges from multiple tax authorities. When production companies operate complex supply chains across jurisdictions, they require sophisticated transfer pricing strategies that withstand regulatory scrutiny while optimizing operational efficiency.

Global manufacturing operations create intricate intercompany relationships that demand precise transfer pricing documentation. Our specialized approach for production companies addresses supply chain complexities while ensuring pricing methods reflect actual value creation and operational realities across all manufacturing locations.

Challenges & Objectives

Before our comprehensive solution, the e-commerce platform faced mounting compliance pressure across rapidly expanding operations:

  • Multi-Jurisdiction Audit – Tax authorities in three countries simultaneously challenged intercompany pricing for raw materials and finished goods transfers.
  • Supply Chain Complexity – Complex production process spanning multiple entities made traditional pricing methods insufficient for regulatory defense.
  • Profit Allocation Disputes – Disagreements over where value was created in the manufacturing process, leading to double taxation exposure.
  • €2.5M Adjustment Threat – Combined tax adjustments from all jurisdictions could have resulted in significant financial impact and ongoing compliance costs.
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Our Approach

We implemented a comprehensive defense strategy combining economic analysis, operational assessment, and strategic restructuring. Our approach focused on demonstrating actual value creation while establishing defensible pricing policies for future operations.

We conducted detailed functional analysis of the entire manufacturing process, identifying key value drivers and risk factors. This enabled us to develop robust benchmarking studies that validated existing pricing while proposing strategic adjustments to enhance compliance and reduce future audit risk.

Our multi-jurisdictional coordination ensured consistent messaging across all tax authorities while addressing local regulatory requirements and establishing sustainable transfer pricing policies for ongoing operations.

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Final Thoughts

Our strategic defense successfully eliminated the €2.5M tax adjustment threat while establishing robust transfer pricing framework for future operations. The manufacturing company now operates with confidence across all jurisdictions with defensible pricing policies.

This case demonstrates how comprehensive transfer pricing expertise can protect manufacturing operations from costly regulatory challenges while optimizing global tax efficiency and operational compliance.

Facing multi-jurisdictional transfer pricing challenges? Contact us today for strategic defense that protects your global operations!

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Our projects

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Tax office secured additional PLN 50,000 revenue by completing comprehensive tax project with our transfer pricing expertise, delivering complete solution in 10 days.

SaaS IT company avoided tax audit and secured 3-year compliance protection through comprehensive benchmarking analysis and updated transfer pricing documentation.

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