International tax and transfer pricing.
Cross-border groups must price transactions between their own companies on an arm's-length basis, document that pricing, and now consider the global minimum tax rules that many countries have adopted. Each country applies these rules through its own law and practice.
What the business is trying to achieve.
CFOs, heads of tax and finance teams of groups with intercompany sales, services, financing or intellectual property across borders.
Intercompany arrangements that are commercially sensible, documented, and coordinated across the countries involved.
From objective to agreed work.
Each step is agreed before it starts. Specialist firms are engaged by you directly and remain responsible for their own advice.
Your commercial objective, markets and constraints are reviewed, and the requirement is restated in plain language.
The decisions are organised in order, with the evidence each depends on and the questions that need qualified advice.
The disciplines and firms needed are identified across the six institutions and the independent firms beyond them.
If you proceed, the coordination scope, deliverables and any coordination fee are agreed in writing.
Where contracted, UNBOUNDED coordinates the work plan, milestones and decision points with the engaged firms.
Defined deliverables.
The deliverables that apply depend on the agreed scope. Professional deliverables, such as opinions, filings and documents, come from the firms you engage.
International tax, transfer pricing, accounting and, where disputes arise, tax controversy specialists.
Clear terms.
UNBOUNDED's role is research and coordination. Regulated legal, tax, audit, financial and other professional advice is provided only under separate engagements.
Tax advice, transfer pricing studies, filings and representation before tax authorities are provided only by qualified firms under their own engagement letters.
Submitting a requirement is free. A coordination fee, where one applies, is agreed in writing once the scope is known. Professional fees are agreed with the firms directly.
UNBOUNDED never takes a referral or success fee from any firm.
Nothing confidential is needed at first contact. Private requirements are never used as general research or for AI training.
A mid-sized technology group charges its overseas subsidiaries a management fee that has never been benchmarked. Its auditors have raised the point, and the CFO wants a coordinated review across three countries.
This example describes a typical situation for explanation only. It does not describe a client, a result or an endorsement.
How to proceed.
Submit the business objective. UNBOUNDED reviews the appropriate next step and, where relevant, proposes a scoped Corridor File.