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Specialized Consulting

Transfer Pricing with strategy for multinationals

For companies with intercompany operations in imports, exports, services, financial transactions or intangibles that need to comply with the new Brazilian rules aligned with the OECD, with security and predictability.

Aligned with the OECD
Master & Local File
Federal Revenue Service

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Some of the companies that have already structured their Transfer Pricing with Apter.
  • Actega
  • Adecco
  • Crown
  • Dynapac
  • Ebara
  • Elliott
  • GDBR
  • GFT
  • Grupo RB
  • Index
  • ITR
Attention

Without a structured policy, the risks only appear when it is too late.

Companies with international operations that do not correctly structure their transfer prices are exposed to tax, financial and operational risks, many of them irreversible.

Exposure to assessments and penalties
Inconsistent pricing models
Vulnerability in audits
Risk of double taxation
Flaws in data collection and structuring
Misalignment with OECD guidelines
Risk of tax adjustments across jurisdictions
Rework and operational inefficiency
Benefits

When well implemented, there is predictability, security and efficiency.

Policies aligned with the business

TP methods and documentation integrated with the group operations.

OECD and Brazil compliance

Complete documentation and justified margins for audits.

Standardized processes

Structured flows reducing dependence on manual controls.

Intercompany transparency

A clear and traceable view of transactions between companies.

Reduced tax risks

Consistent policies that reduce tax exposure.

A more strategic team

Less operational effort, more strategic decisions.

Simulations with real data

Models tested with real data for predictability.

Audits with confidence

Organized documentation for inspections and reviews.

How we work

A methodology that delivers concrete results.

From analysis to implementation, we cover every stage to structure and maintain your Transfer Pricing policy.

  1. 1

    Complete policy diagnosis

    Analysis of intercompany operations, contracts, margins and pricing models.

  2. 2

    OECD implementation or review

    Adjusting the policy to the methods required by Brazilian and international rules.

  3. 3

    Documentation and compliance

    Preparation of Master File, Local File and other mandatory documents.

  4. 4

    Ongoing support

    Monitoring of policies, periodic adjustments and support during inspections.

  5. 5

    Validated tools and processes

    Standardized flows that reduce time and errors in the process.

Differentiators

Why choose Apter?

Specialized and dedicated Transfer Pricing team

Efficient, data-driven methodology

Tailored approach for each business model

Full alignment with the OECD and the Federal Revenue Service

Internationally recognized tools

Step by Step

How to get started

From the first meeting to ongoing support.

1Scheduling the initial meeting
2Mapping the transactions
3Review of Transfer Pricing contracts and policies
4Benchmarking study
5Method selection and calculation
6Documentation and delivery
7Ongoing support

Structure your Transfer Pricing with those who understand it. Start now.

Schedule Meeting
Next step

Reduce tax risks and face audits with complete confidence.

Talk to our team and find out how to structure your Transfer Pricing policy efficiently and in line with OECD guidelines.

Guaranteed compliance
Complete documentation
Dedicated TP team
Schedule Initial Meeting