QCG Transfer Pricing Practice
Go Lean. Go Smart. Go QCG
QCG is a specialized transfer pricing practice helping our clients comply with international transfer pricing obligations and properly align their intercompany transactions developing new approaches to improve their financial and tax performance. Our clients include over three hundred multinational companies worldwide that through our counsel have successfully implemented adequate transfer pricing positions and met international obligations.
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New approaches to improve your financial and tax performance
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Key Features
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Our solutions are the most efficient and innovative in the market. A multidisciplinary team of experts including accountants, economists and lawyers, along with mathematical models and big data tools, allows us to have a full understanding affecting your business.
Our team closely collaborates with the most prestigious national and international media. QCG professionals are frequent contributors to IDC Prรกctica Fiscal, Thomson Reuters, MNE Tax, and TP Minds. We also provide regular feedback to OECD international tax publications.
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QCG Transfer Pricing practice leadership are renown professionals. QCG’s leadership is part of important chambers of commerce, professional organizations and top universities in the country.
QCG is business partner of Thomson Reuters in Mexico for transfer pricing purposes. Together we empower solutions for the alignment of BEPS practices and the compliance of the Country by Country report.
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QCG leads the transfer pricing certification process in Mexico. Sponsored by the Mexican Federation of Economists, and supported by the most important tax practices in the country, QCG has led the way in the certification process for transfer pricing professionals in Mexico. This breakthrough certification program is among the first of its kind worldwide, and offers clients and tax authorities assurances of the quality of these individuals. As of 2019, QCG accounts for 1/5 of all certified experts. 5
Services
Our firm has been nominated as the best transfer pricing firm in Mexico by International Tax Review 6
Intercompany Organization Internal Supply Chain Optimization Compliance Support Consulting BEPS Advice Foreign Trade International Taxation Legal Counsel Valuation Services 7
Intercompany Organization (Alignment of transfer pricing outcomes)
An adequate transfer pricing system starts considering the analysis of the business. Reasons behind each intercompany transaction, and its legal, accounting, tax and transfer pricing treatment. Our firm can assist you in evaluating such scenarios and choosing the best option considering your needs.
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Internal Supply Chain Optimization Optimizing intercompany transactions through the use of mathematical models and Big Data. Today most multinationals first minimize costs by varying production and logistic parameters and only then align transfer prices. Such approach does not guarantee the true operational and financial optimum. We have developed innovative solutions using mathematical models, new computer algorithms, and Big Data tools that will allow you to find the true maximum profit after taxation. Our new approach streamlines the engagement process, reducing costs and increasing efficiency, resulting in better and cleaner deliverables. 9
Compliance Support Perhaps the most frequent concern about transfer pricing is compliance. Nowadays, taking into account the new norms suggested by the OECD in Action 13 of its BEPS plan, is necessary to develop a coherent, integrated and accurate approach to demonstrate the arm’s length value of the intercompany transactions across the entire organizaÂtion. Additionally, Our firm can assist you in bilateral or multilateral APA negotiations. For the maquiladora industry we can help you to evaluate the safe harbor options provided by the Mexican Tax Authorities.
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Consulting Important issues arise every day related to the administration of any transfer pricing scheme. How to organize intercompany transactions? What are the tax implications of the operation, both domestically and internationally? What transfer pricing risks does the current business model hide? How to allocate the expenses derived from service provisions? How to organize a centralized treasury model? These are examples of frequent questions that are solved by our firm in a precise and expeditious manner.
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The BEPS plan modifies the international tax system
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BEPS Advice The OECD Action Plan on Base Erosion and Profit Shifting brings a new era for multinational companies. The expected changes to the global tax framework are of such a magnitude that they will affect the OECD Model Tax Convention, the network of international treaties on double taxation, and the current Transfer Pricing Guidelines. A thorough review of the current transfer pricing and international tax policies is necessary for multinational groups to anticipate the effects of the Plan and adjust their operations accordingly.
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Foreign Trade Our firm deals with experienced partners who can advise you on legal and customs matters, attend to foreign trade processes, carry out customs tariff classification studies, devise models for operations, provide legal defense against customs and foreign trade matters, perform preventive audits, and also train your staff on topics of interest in this field.
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International Taxation Correct interpretation of income tax treaties is essential to gain tax advantages. Issues like royalty or interest payments, identification of tax havens, use of favored national clauses, or issues triggered from the existence of a permanent establishment, are some aspects routinely addressed by our practice. We also can assist in evaluating tax implications of M&A, sale of shares, deferred taxes, and HQ reporting.
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Legal Counsel Nowadays transfer pricing and international tax disputes are frequent. Our legal practice brings together attorneys at law well trained in transfer pricing, international tax, and even domestic taxation issues with the objective to assist you in any tax controversy, prepare your intercompany agreements or negotiate your intercompany transactions.
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The number of transfer pricing audits are increasing dramatically
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Valuation Services We offer valuation services, following both the domestic and the international standards, to estimate the fair market value (FMV) for different assets, such as minority and/or majority shareholders’ interests, intangible assets (trademarks, patents, software, client list, etc.), and going concern privately-owned businesses.
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Our valuation studies, follow the standards accepted in Mexico, the US (by NACVA, National Association of Certified Valuators Analysts) and Canada (CICBV, Canadian Institute of Certified Business Valuators), supporting a wide range of purposes, including:
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Transfer pricing reports Capital gains estimate Mergers and Acquisitions Entrance and exit of shareholders Financial reporting and price allocation Corporate restructuring Litigation Support
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Success Cases
Food & Beverage Industry We realigned the transfer pricing policies of one of the most important bottling groups worldwide, including the restructuring of its domestic intercompany transactions.
Hotels & Leisure We realigned the intercompany transactions within the Mexican subsidiaries, and provided valuable feedback to handle the global cash pooling (with more than 150 affiliates worldwide), helping the company avoid substantial transfer pricing penalties. 20
Automotive We successfully guided a mayor German manufacturer through a transfer pricing audit in Mexico, reducing the initial penalty by 75% (over 30,000,000 USD).
Information Technologies We assisted a leading Spanish (HQ) IT company to document its intercompany transactions throughout Europe and Latin America.
Services We provided assistance to a Colombian subsidiary of a service company to avoid important permanent establishment issues due to its organizational structure.
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Contact Mexico City Sófocles 127, piso 3. Los Morales Polanco 11510, Mexico City. +52 (55) 53951968
Bogotá Kr 17 No. 88 23 ofic. 303. Edificio Cezanne, Bogotá. +57 (1) 7551948/49 – 6105955
Chicago 300 W Madison St. Suite 2100 Chicago, Il 60606. +1 (312) 277 4021
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New approaches to improve your financial and tax performance
qcgtransferpricing.com