Transfer Pricing Services
Practical compliance, specialized expertise, and rapid delivery across jurisdictions
2,500+
tailored reports delivered across alternative investment structures
30+
jurisdictions covered with one integrated team
20+
transfer pricing professionals specialized exclusively in alternatives
What our Clients say:
Why Transfer Pricing is critical for Alternatives
Transfer pricing obligations affect every stage of the investment lifecycle. From fund structuring and refinancing to acquisitions and exits, documentation must not only comply with OECD BEPS rules but also withstand scrutiny from local tax authorities.
Without the right support, managers face:
- Costly penalties and adjustments if reports are incomplete or late
- Transaction delays when documentation is missing at closing
- Reduced investor returns from inefficient structures or incorrect valuations
Why Partner with Alter Domus
Alter Domus combines deep technical knowledge with practical delivery tailored to the needs of alternative investments:
- Specialized Expertise: team dedicated exclusively to alternatives, ensuring strategies are designed for real estate, private equity, private credit, and debt structures.
- Proven Delivery: Reports delivered within three weeks as standard, with urgent cases completed in as little as 24–48 hours, giving managers confidence that deadlines won’t derail critical transactions.
- Trusted Partnerships: Collaboration with a network of leading tax law firms across Europe to provide full compliance coverage across jurisdictions.
- Transparent Pricing: Predictable fee structures with no hidden costs, so managers can budget with certainty.
Our transfer pricing services are designed around the real needs of alternative investment managers. Focused on the most critical compliance requirements, we provide specialized solutions that keep structures compliant, transactions efficient, and stakeholders confident.
Our Core Transfer Pricing Services
Interest Rate Benchmarking Analyses
- Provide cross-jurisdictional benchmarking of intercompany financing
- Deliver defensible, market aligned interest rates that meet regulator and auditor expectations
- Safeguard financing structures against penalties, tax adjustments, and delays
Equity-at-Risk and Margin Analyses
- Assess Luxembourg holding structures to ensure equity levels and margins comply with regulations
- Strengthen audit defensibility and minimize tax authority risks
- Provide investors with confidence in a complaint, sustainable capital structures
Preparation of
Local Files & Master Files
- Prepare OECD BEPS-complaint documentation across 30+ jurisdictions
- Ensure consistent fulfillment of mandatory reporting obligations
- Support audit readiness and streamline financial reporting
- Protect against penalties and compliance challenges, ensuring smooth transactions
When to Engage Us
Clients gain the most value from our transfer pricing expertise when we are involved early in the investment cycle. Engaging us before transactions are finalized allows structures to be set up on solid ground, and avoids the challenges of retroactive justification.
Acquisitions or divestments
Providing defensible documentation to support due diligence and smooth closing.
Loan refinancing
Ensuring financing terms align with market standards
Restructuring
Guiding efficient reorganizations across multiple jurisdictions.
Cross-border distributions
Minimizing risks from complex, multi-country transactions.
Audit preparation
Delivering robust reports that meet regulator and auditor review
FAQs
Do I need a transfer pricing report if I already have a fund administrator?
Yes. Fund administration does not replace transfer pricing compliance. Regulators require standalone transfer pricing documentation to demonstrate compliance with OECD and local rules. Many mangers assume their administrator covers this, but it is a separate obligation. Alter Domus provides transfer pricing reports on a standalone basis, so managers can stay compliant without changing or restructuring their existing administration setup.
How quickly can a transfer pricing report be delivered for a deal?
Transfer pricing reports are normally completed within three weeks, depending on the complexity of the structure and the availability of information. At Alter Domus, our dedicated team can accelerate delivery when deadlines are tight, ensuring compliance without compromising quality.
What are the key transfer pricing requirements for cross-border funds in Europe?
European regulators require funds with cross-border operations to maintain OECD-compliant transfer pricing documentations, typically including a master file and local files, as well as support for intercompany financing arrangements. These obligations apply regardless of who administers the fund. At Alter Domus, we prepare this documentation in line with BEPS standards and tailor it to fund structures, including SPVs, so that it withstands both local audits and investor scrutiny.
Get in touch with our Transfer Pricing Team
Contact us today to learn how Alter Domus can help you safeguard compliance, reduce risk, and keep transactions moving.
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