UK/Cyprus: Global Fund Manager (EUR 3bn)
Advising on transfer pricing of the intra-group transactions of the fund companies, and advising on the new risk analysis framework – six step process following BEPS Actions 8-10 for identifying and analysing risks.
UK: Treasury company investing in distressed debt, for a large UK Pension Fund (GBP 7bn)
Transfer pricing evaluation of the interest and gain components related to distressed debt of intermediary financing companies, including the credit evaluation and expected recovery rates of the borrowers.
Cyprus: Trading Platform Valuation (EUR 300m)
Prepared a valuation for the transfer of software for a trading platform and obtained tax rulings in Cyprus regarding the IP regime, and abroad securing tax certainty regarding royalty rates applied.
Asia: Restructuring for Luxury products multinational (>EUR 10bn)
Designed a new transfer pricing global policy for a large Asian multinational operating in the retail business of luxury products, preparing documentation and negotiating various APAs in various countries.
Israel: Valuation of intangibles for an Entertainment and Gaming Group (EUR 100m)
Valuation of various marketing intangibles being sold, in relation to products in the entertainment and gaming industry.
US: Intra-group financing for R&D activities of a major US technology multinational (USD 2.5bn)
Providing transfer pricing advice on structuring various financial instruments through Cyprus, granted from the US ultimately to European subsidiaries of a US technology multinational. The subsidiaries were engaged in “blue sky” (high risk) research and development activities.
Luxembourg / Singapore / Cyprus: Treasury company of major real estate fund (EUR 1.5bn)
Advised on setting-up full-fledged treasury companies in Luxembourg and Singapore of a Cyprus-based regulated fund, investing in Asian and European real estate.
Eastern Europe: TP litigation support for Original Equipment Manufacturer (OEM) (EUR 400m)
Developed a transfer pricing model to map, in particular, key functions and intangibles explaining the group’s profit allocation, successfully employed in the context of tax litigation for a OEM operating in Eastern Europe.
Netherlands / Belgium: Transfer of portfolio of loans from a Private Bank provided to online entertainment start-ups (EUR 3bn)
Advised on the transfer of a large portfolio of intra-group loan receivables from Belgium to the Netherlands, and negotiated an APA with the Dutch tax authorities. The loans had been granted to online gaming and online casinos start-ups, and the project included a valuation of the gain realised upon the transfer of the portfolio of loans.
LATAM: Parent guarantees to issue bonds to the market to acquire a pharma Company in LATAM (USD 2bn)
Advised on the transfer pricing aspects of parent company financial guarantees, including an element of performance guarantee, to issue bonds to the market and use the proceeds to acquire a LATAM pharmaceutical.
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