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Staying Ahead of OECD Framework: BEPS

Quantera Global provides high quality, pragmatic transfer pricing planning, support and insights based on our extensive Asia-Pacific experience and local knowledge, for our clients.

Quantera Global is one of the world’s leading, independent transfer pricing advisory firms, providing specialist transfer pricing planning, compliance and advisory support services to multinationals, globally.

Our business is transfer pricing. We provide specialist transfer pricing services to clients through our seamless network of experienced practitioners and select alliance partners. Clients trust us to deliver best-quality transfer pricing advice and service that is pragmatic and reflects current cross-border jurisdictional requirements, without losing sight of the technical details and operational impacts.

Our clients value our capability and depth of technical expertise in specialist areas such as:

  • design of TP systems and pricing policies,
  • interest rate and guarantee fee transaction benchmarking, and
  • preparation of master and local file reports.

Our Asia-Pacific experience and local country knowledge let us bring real insights to clients, to streamline their processes, reduce TP risk and improve compliance, as well as to identify and implement opportunities.

Clients appreciate that with Quantera Global, senior practitioners are fully involved in service delivery throughout each project. Our highly experienced professionals, smart and efficient internal processes and high standards of service.




  • Strategic coaching
  • Strategic review to identify Transfer Pricing risks and opportunities for improvement
  • Design of operational Transfer Pricing policy, business processes and scenario analysis
  • BEPS risk review and compliance strategy development
  • Functional characterisation / re-characterisation and analysis
  • Benchmarking studies & financial modelling


  • Master and local file documentation
  • Country-by-country reporting
  • Transaction-based documentation
  • Transfer Pricing review of legal agreements
  • Documentation of Transfer Pricing policies and assistance with implementation
  • Provision of in-house and ad-hoc Transfer Pricing support on a retainer basis


  • Transfer Pricing risk assessment and prudential risk reviews
  • Strategic audit management
  • Unilateral, Bilateral or Multilateral
  • Advanced Pricing Agreements
  • Mutual Agreement Procedures
  • Arbitration, mediation and expert witness testimony/opinion


What our clients tell us are their issues And how Quantera Global Assists
1. How do I stay abreast of relevant TP changes and risks across the region – and know when to take action?
  • Development of strategic BEPS compliance plan that addresses the complexity of issues across the region
  • Investing in understanding and advising clients on timing of BEPS
2. How do I address TP compliance and issues in a cost- effective manner – with limited resources and budget?
  • Providing a range of flexible inhouse and/or ad-hoc TP support packages to provide only the support that clients require
  • Joint Quantera-client project teams for effectiveness
3. Am I doing all that I can to minimise risk, optimise compliance and drive value in our Asia-Pacific operations?
  • Strategic TP review to determine risks and opportunities
  • Prudential risk reviews to bolster corporate governance
  • BEPS review to identify near-term compliance risks and actions
  • Developing and implementing pragmatic TP policies and processes, that work in local jurisdictions in Asia- Pacific
4. How do I respond to multiple TP audits and investigations with tax authorities in multiple jurisdictions in Asia-Pacific?
  • Senior TP practitioners on the ground, who are experienced in managing complex TP audits to a successful conclusion
  • Senior practitioners bring constructive relationships with local tax authorities and can anticipate direction of audit outcomes
  • Significant APA experience in Asia-Pacific


1. Realising value earlier (reduced costs/ risks)
  • TP is our business – we bring our experience in Asia- Pacific markets to design pragmatic and sustainable TP solutions, that work and are commercial in local markets
  • We right-size our support, offering flexible ad-hoc, in-house and project TP support to provide real value for money while helping clients to address their specific needs
  • We provide best quality technical advice: senior experience as well as inhouse tax and tax administration experience on the ground.
2. Realising a greater level of value (lower risks/higher after-tax profits)
  • We invest in understanding our client’s business and proactively provide timely advice on changed TP requirements, which impact their compliance and risk profile
  • The Width and depth of our Asia-Pacific network means that we can assess each client’s TP risks and advise on planning opportunities throughout the region.
  • We undertake periodic reviews for clients to determine if their TP model still supports effective risk management and compliance in key jurisdictions and recommend opportunities to improve the model – working with clients to implement any revisions
  • We deliver a full suite of transfer pricing solutions (from strategic coaching, design, documentation through to strategic audit defence and partnering with clients to help them manage complex disputes), providing tailored support.
  • We operate as one global team providing seamless and consistent support, project management and co-ordination with clients for high quality outcomes


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