Private Equity & Transfer Pricing

Why is Transfer Pricing important for Private Equity Funds? 

For private equity funds, transfer pricing is not only key but necessary to ensure your structure is optimized while aligning with international best practices.  Our broad private equity client base often tells us that transfer pricing is a top priority because:

• The due diligence process focuses heavily on historical transfer pricing approaches applied by the fund, portfolio companies and assets to assess financial health and tax compliance. In many cases, when exiting an investment, transfer pricing policies and overarching approaches to transfer pricing compliance can impact deal pricing or in some cases even lead to deal termination.
• Aligning transfer pricing with the fund's operating model, private equity funds can align the overarching strategic goals of the funds with transfer pricing strategy. As such, our clients tell us that transfer pricing is not only a “nice to have” but is essential to drive the success of the business.
• In many jurisdictions it is a legal and regulatory requirement to ensure transactions such as intercompany debt and interest, management fees, transaction fees, monitoring fees and origination fees are arm’s length in nature.
• Recent tax developments such as Amount B, Pillar 2, Trump tariffs and related supply chain management, make it particularly important for businesses in the private equity space to ensure that the transfer pricing approach adopted is robust and in line with international best practices.  

How can Meijburg help? 

The KPMG Meijburg Financial Services Transfer Pricing team is market-leading in the private equity sector, bringing cutting edge solutions and market insights to help you on your transfer pricing journey.

Our services include: 

• Transfer pricing health checks and diagnostic analysis to help align transfer pricing with the business objectives and tax landscape.
• The design and implementation of 100-day plans to ensure that when onboarding new assets there is a smooth transition between pre- and post-deal operations.
• Transfer pricing policy design to optimize your structure and approach to transfer pricing.
• Internal governance and operating frameworks to help ensure that the business prioritizes alignment between transfer pricing and operations.
• Implementation support to help you with the practical considerations of putting transfer pricing policies into practice.
• Transfer pricing compliance assistance to help with Local Files, Master Files, CbCR and benchmarking. 

Our approach to transfer pricing for private equity clients is flexible and customized, driven by the specific needs, culture and strategic goals of our clients. We work with you throughout your private equity transfer pricing lifecycle to review, design and implement a transfer pricing framework and methodology that is future-proof for all your deals as your business grows and evolves within the ever-changing transfer pricing landscape.