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Case Study 1: Transfer Pricing Restructuring (India/Europe)

A client wished to establish a single global production facility in India to replace older production plants in Europe and North America. WTP Advisors provided transfer pricing analysis and structuring advice regarding the planned establishment of a manufacturing facility in India to be constructed within a Special Economic Zone. We analyzed the proposed transfer of plant design and manufacturing technology from Asia and Europe, reviewed and recommended transfer pricing modifications to the global supply chain for finished products, and prepared a defensive transfer pricing study and documentation to mitigate potential taxation of the restructuring by European tax authorities. 


The scope of our work included performing a global transfer pricing analysis and providing input into intercompany sales and distribution agreements, intangibles licenses, and manufacturing services agreements for all participating entities in Asia, Europe and the Americas. In order to support the allocation of risk in our pricing model, we worked closely with the client’s project management team to ensure that all licensing, production and distribution agreements were formalized before the new plant became operational. The global nature of this transfer pricing project required us to develop solutions for manufacturing, distribution and margin changes among three separately-managed regions.

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