MONTCLARE
CAPITAL PARTNERS
Transfer pricing is where tax authorities look first. Montclare designs and documents the pricing of transactions between related entities so it is benchmarked, documented and commercially coherent — able to withstand scrutiny in the jurisdictions where the group operates.
Comparable-company analysis using CUP and TNMM methods to set defensible arm's-length pricing.
Master File and Local File prepared in line with OECD BEPS Action 13.
Drafting and review of intra-group contracts that match the functional and economic reality.
Valuation and pricing of intangibles and intra-group royalties under the arm's-length principle.
Support files for tax-authority reviews (Belastingdienst, AEAT).
Aligning the group's substance, functions and risks with its pricing policy.
Most firms either structure or price. Montclare does both — so your transfer pricing is consistent with your holding structure, your substance and your tax position across the Netherlands, Spain and beyond. One coherent narrative, not three disconnected opinions.
This page is informational and does not constitute tax advice. Each engagement is subject to scope and applicable regulation.
An international software group with a holding company, an IP-owning entity and local commercial and delivery arms faced an unclear question: not only where profit sat, but how each company was remunerated for the functions it actually performed.
We reviewed the functions, assets and risks across each entity and helped define an intercompany pricing framework, advising that software licensing, maintenance, support, platform access and brand rights be separated rather than bundled into one generic royalty line, coordinating specialist transfer pricing advisers where benchmarking was required.
A clearer, DEMPE-aligned intercompany framework with a stronger documentary trail and reduced risk of unsupported profit shifting, where supporting conditions and local documentation requirements are met.
A complete technical series on Dutch transfer pricing, from the documentation duty that applies to every group to the specific transactions that attract scrutiny.
Ten questions that reveal, in three minutes, whether your intercompany pricing would survive scrutiny. In the Netherlands, Article 8b requires every company with related-party transactions to price them at arm’s length — and to document how — regardless of size.
DOWNLOAD THE CHECK · PDFWe do not name clients. Discretion is part of the service.
A B2B software group with recurring revenue, between thirty and one hundred employees and customers across several markets, operated through a European parent and local commercial subsidiaries. Management fees, operational support, funding, commercial functions and the use of intangibles all moved between entities. Very little of it was documented.
Outcome. The group holds a defensible intercompany policy aligned with OECD standards. The objective was never to reduce tax artificially; it was to remove the risk of adjustment. In a group operating across several jurisdictions, a properly supported policy materially lowers exposure to adjustments, penalties and double taxation.