Transfer Pricing Advisory
A high-quality, efficient and pragmatic advisory practice for multinational groups — transfer pricing policy, documentation, and benchmarking analyses, with particular depth in intragroup financing. Through focused project management, we dedicate the necessary time and resources to each client, maintaining a superior level of technical precision and a highly personalized service experience.
What we do
Each engagement starts from the group's real intercompany transactions, shaped to fit the business and the regulatory context it operates in.
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 transfer pricing positions across multiple jurisdictions globally and achieving significant reductions in tax exposure.
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
Founder & 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 16-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
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.
info@lemantax.com