transfer pricing

Transfer Pricing Experts
with Extensive Experience
in Multinational Advisory

The ETL GLOBAL Transfer Pricing Working Group is a European team of experienced international tax experts within the ETL GLOBAL Network. Together they provide reliable, practical guidance to multinational businesses in transfer pricing matters and help them find their way in the ever changing world of rules and legislation.

The ETL GLOBAL Transfer Pricing Working Group is dedicated to making transfer pricing less complicated for businesses, helping them meet global tax standards easily. This way, international clients can focus on their business and on achieving their commercial goals.


Master File and Local File Documentation

Compliance for transfer pricing purposes according to the OECD Guidelines and the specific requirements of the respective jurisdiction.

Country by Country

Elaboration of Country by Country reports.

Benchmarking Studies and Comparability Analysis

Benchmarking and comparability studies according OECD Guidelines in compliance which each jurisdiction.

Interquartile ranges for tangible and intangible intercompany transactions, considering financial, services transactions as well as intangible transactions among related parties.

Transfer Pricing Audits

Assistance in administrative procedures with the tax authorities, including controversies in economic and administrative aspects.

Transfer Pricing Policy Design

Design and implementation of transfer pricing policies, considering the value chain within the related parties transactions.

Identification and categorisation of the intercompany transactions.

Transfer pricing policies aligned with the arm’s length principle and according to the OECD Guidelines methodology.

Assistance in the implementation and complete documentation of transfer pricing policies, considering the client’s internal procedures.

Identification of Risks

Companies face an increasingly complex business environment. Advice on planning, execution, risk management, documentation and dispute resolution is essential to achieve their commercial objectives.

Tax Authorities are aware of specific risk areas, such as:

  • Restructuring operations.
  • Business model.
  • Transmission of intangibles among related parties.
  • Intragroup services.
  • Recurrent operating loses.
  • Economic substance in intercompany transactions.
  • Reliable benchmarking studies (quantitative and qualitative screening.)
  • Intragroup financial transactions (interest rates).
  • Segmented financial information for intercompany transactions.
  • Documentation of mark-ups applied.
  • Allocation of benefits and costs in intercompany transactions.

APAs (Advance Pricing Agreements) and MAPs (Mutual Agreement Procedures)

Preparation or verification of a cooperation model between related entities in order to submit an application for an Advance Pricing Agreement.

Support in preparing an application for an Advance Pricing Agreement and in developing the transfer pricing documentation requirements.

Transfer pricing consulting in negotiations and in the process of obtaining an Advance Pricing Agreement.

Support in the preparation of the application for initiating the Mutual Agreement Procedure in the case of double taxation, as well as support and representation in international administrative proceedings.


Eric Talabardon French Desk

Arely Almaguer

Western Europe

Arely Almaguer is a highly experienced professional with more than 15 years in the field of transfer pricing services. Her career has been distinguished by significant contributions to multinational projects, developed during her tenure at prestigious global consulting firms.

Arely specialises in crafting and implementing transfer pricing policies through comprehensive economic and financial analysis. Her deep understanding of this field ensures her clients’ compliance and operational efficiency. Notably, she excels in identifying and analysing intangible assets and business restructuring, making her a sought-after expert for global businesses.

As head of the ETL GLOBAL Transfer Pricing Working Group in Western Europe, Arely oversees a variety of projects, particularly in the Spanish market. Her responsibilities include managing benchmarking studies, conducting risk analysis, and ensuring strict compliance with transfer pricing documentation for related operations. With her extensive knowledge, Arely continues to make a significant impact on the complex field of transfer pricing in Europe.

Eric Talabardon French Desk

Magdalena Dymkowska

Eastern Europe

Magdalena Dymkowska, is Partner in a practice of nearly 50 people – one of the largest and most awarded transfer pricing practices in the Polish market. She is heading the working group of the Transfer Pricing Forum on the TP-R declaration under the Ministry of Finance in Poland.

Magdalena is responsible for the implementation of projects in the area of transfer pricing concerning, amongst other things: design of intragroup settlement models, preparation of comparability analyses (benchmarking studies) for, inter alia, manufacturing, distribution, services (including transactions related to the development of IT applications and systems), financial or licensing activities, as well as preparation of transfer pricing documentation.

Magdalena brings along broad experience in conducting projects regarding the analysis of restructuring processes in terms of their compliance with the transfer pricing rules, as well as defense of the arm’s length nature of intragroup settlements during tax audits.  Her responsibilities include also managing APA (unilateral and bilateral) proceedings.

Download the TRANSFER PRICING GUIDE 2023/24

Equip yourself with the knowledge necessary for effective management and compliance in the dynamic realm of cross-border transactions and download the Transfer Pricing Guide 2023/24.

ETL GLOBAL Transfer Pricing News

Global Minimum Tax For Large Companies In Spain

Global Minimum Tax For Large Companies In Spain

This measure is part of the international tax reform promoted by the OECD to address the tax challenges arising from the digitalisation of the economy, within the framework of the initiatives against Base Erosion and Profit Shifting (BEPS). It is part of "Pillar 2" of...

Significant Tightening of Transfer Pricing Rules in Germany

Significant Tightening of Transfer Pricing Rules in Germany

I. Transfer Pricing in Germany: Initial Situation Business processes of a globally active company are distributed worldwide due to the increasing convergence of markets. Those countries in which companies are active would un­derstandably like to tax a portion of the...

"The ETL GLOBAL Transfer Pricing Working Group comprises specialists from all across Europe. They remain in constant training and, through the ETL GLOBAL Network, share experiences, knowledge, and technical skills."

ETL Global



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