Transfer Pricing Advisory
A senior transfer pricing practice for multinational groups — from GAP Analysis and policy design to benchmarking, documentation, and dispute defence. One experienced advisor on your file, from the first call to the final deliverable.
No intake forms · No account managers · Direct response within 24 hours
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.
Illustrative examples of cross-border related-party flows — for reference only.
Method: Cost plus / TNMM · Benefit test · OECD Chapter VII
Method: CUP · Credit rating analysis · OECD Chapter X
Method: CUP / Profit split / TNMM · DEMPE analysis · OECD Chapter VI
These diagrams are illustrative examples of common intercompany structures. They do not constitute tax advice and do not represent any specific client situation.
Starting point
Most popular first engagementNot sure where your transfer pricing stands? A GAP Analysis is a structured diagnostic of your current intercompany structure and operations — identifying compliance gaps, pricing risks, and strategic 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 AnalysisEach engagement is scoped to what the group actually needs — not a standard package delivered by a rotating team. Every file is personally managed from day one.
Policy design, intragroup transaction structuring, benefit test analyses, and transfer pricing planning — built around the group's actual operations and the regulatory environment it operates in.
Local file, Master file, and Country-by-Country Reporting — prepared once and adapted efficiently across every jurisdiction the group needs to file in, with positions that hold up under scrutiny.
Mark-up estimation for intragroup services and interest rate benchmarking for intercompany loan transactions — the technical foundation of any defensible transfer pricing position, and a particular area of depth here.
Support across tax authority audits, information requests, and cross-border transfer pricing disputes — drawing on direct experience defending positions at both Big Four advisory and in-house leadership level across multiple jurisdictions globally.
Compliance backed by quantitative precision. Compass is our proprietary financial infrastructure powering debt pricing analyses across European and Latin American markets — bridging the gap between transfer pricing compliance and financial market realities to deliver arm's length interest rate benchmarks for both standard corporate loans and highly structured real estate financing.
From standard intragroup working capital loans to complex European REIT and Private Equity structures. Compass models synthetic credit ratings by adjusting for corporate metrics or property-level risk premiums such as LTV.
Data-driven yield curves and comparable debt analyses calibrated for international transactions, ensuring full compliance with local tax authorities and the OECD Guidelines, including Chapter X on Financial Transactions.
Deployable as a transactional pricing report during deal due diligence, or as a recurring review service aligned with your corporate reporting calendar.
Compass is developed and maintained in-house. It is not a third-party platform.
Leman is a boutique transfer pricing advisory practice built on the belief that the best transfer pricing work is both technically rigorous and genuinely implementable. Having spent over a decade in complex tax environments — as a Big Four advisor and as the person responsible for defending those positions in-house — we understand what actually holds up when a tax authority pushes back.
We don't produce reports that sit in a drawer. Every engagement is designed around what the business can actually execute — policies that match the operational reality, documentation that addresses the real risks, and pricing positions that are commercially coherent and legally defensible.
Engagements are delivered through Leman Tax Advisory SpA, based in Chile, with experience across Chilean transfer pricing regulations and multi-country Latin American structures.
Principal Advisor
Over 13 years in transfer pricing and international tax, split between Big Four consulting and senior in-house roles across Europe and Latin America. Began in transfer pricing at PwC Chile, then moved through PwC Luxembourg and KPMG Germany advising Financial Services and Private Equity clients on complex cross-border structures.
Subsequently led the global tax and transfer pricing function of a large data-technology group — including a €4b merger due-diligence, a multi-country carve-out, the pricing of all related intragroup transactions, and the post-merger harmonization of a decentralized transfer pricing model into a centralized operating structure.
Has managed transfer pricing audits and disputes with tax authorities across multiple jurisdictions globally, achieving significant reductions in tax exposure — with direct knowledge of what tax authorities look for and how defensible positions are actually built.
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
LL.M International Business Taxation, Tilburg University · LL.M Taxation, PUC Chile · MBA, PUCV Chile · Business Administration, UDD Chile
English (fluent) · Spanish (native)
Whether it's a first-time question about whether transfer pricing applies to your business, or a specific issue with an existing structure — tell us about your business and operations, and we will take care of the rest.