Transfer Pricing Advisory
A lean, project-based advisory practice for multinational groups. From GAP Analysis to full documentation, benchmarking, and dispute defence — with the depth of Big Four expertise and the directness of a senior specialist working on your file personally.
Who we work with
Transfer pricing rules apply whenever a company transacts with a related entity — a subsidiary, a parent, or a sister company — across two or more countries. This applies regardless of company size, sector, or how simple the structure looks.
Particular depth in Latin American and European cross-border structures, with experience in LatAm-Europe corridors, multi-jurisdictional groups, and companies expanding across regions for the first time.
We work directly with the people making the decisions — business owners, CEOs, and finance teams. If you're not sure whether transfer pricing applies to you, start with a conversation.
Starting point
Not sure where to start? Many engagements begin with a GAP Analysis — a structured diagnostic of your current intercompany structure and operations, identifying gaps, risks, and opportunities, with a clear recommended path forward.
This is typically the entry point for new clients who have not previously addressed transfer pricing, or are expanding their operations across borders for the first time.
Request a GAP AnalysisWhat we do
Each engagement is scoped to what the group actually needs — not a standard package delivered by a rotating team.
Advisory and consultancy on intragroup transactions, transfer pricing policy design, benefit test analyses, and transfer pricing planning — built around how the group actually operates, not a generic template.
Local file, Master file, and Country-by-Country Reporting — prepared once and adapted efficiently across every jurisdiction the group needs to file in.
Mark-up estimation for intragroup services and interest rate benchmarking for intragroup loan transactions — the technical core of any defensible transfer pricing position, and a particular area of depth here.
Support across transfer pricing audits, tax authority enquiries, and cross-border disputes — drawing on experience at both Big Four advisory and in-house leadership level, defending positions across multiple jurisdictions globally and achieving significant reductions in tax exposure.
Technology
Structured process, applied consistently: Compass is the proprietary infrastructure behind our benchmarking work, built in-house as one expression of the technology-driven approach that runs through how we work — delivered as a one-off analysis, or as a recurring benchmarking service for groups with ongoing intragroup financing activity.
Compass is developed and maintained in-house, supporting our benchmarking analyses across the practice.
Approach
Leman is a boutique tax advisory practice that uses technology and structured processes to provide international tax advisory services to medium-sized and large companies, specializing in transfer pricing. Engagements are delivered through Leman Tax Advisory SpA, based in Chile, with particular familiarity with Chilean transfer pricing rules and multi-country LatAm structures.
Our practice is built on solid technical expertise and extensive practical experience in the industry. Having developed our careers in complex tax environments, both as advisors (Big Four) and in the corporate sector, we have firsthand understanding of the internal pressures and external regulatory demands our clients face. We don't just produce reports; we work closely with your team to ensure our solutions are implementable, defensible, and fully aligned with your business objectives.
Background
Principal Advisor
13+ years in transfer pricing and international tax, split between Big Four consulting and in-house leadership, across Europe and Latin America. Started in transfer pricing at PwC Chile, moved through PwC Luxembourg and KPMG Germany advising Financial Services and Private Equity clients, then led global tax and transfer pricing functions in-house at a global data-technology group — including a €4b merger due-diligence, a multi-country carve-out, and the pricing of all related intragroup transactions.
He has also led post-merger harmonization of decentralized transfer pricing models into centralized operating structures, and managed transfer pricing disputes with tax authorities across multiple jurisdictions globally, achieving significant reductions in tax exposure.
PwC (Chile, Luxembourg) · KPMG Germany · Head of Group Taxes & Transfer Pricing · Finance (Tax) Transformation
Technology & SaaS · Pharmaceutical & Medical Devices · FMCG & Manufacturing · Metals & Mining · Financial Services · & Others
Master in Law (LL.M) in International Business Taxation, Tilburg University · Master in Law (LL.M) in Taxation, PUC Chile · MBA, PUCV Chile · Business Administration, UDD Chile
English (fluent) · Spanish (native)
Get in touch
Whether it's a single intercompany loan or a full policy redesign across several countries, the first conversation is with the person who'll actually do the work — no intake forms, no account managers.