Clear, strategic and client first
Transfer pricing advisory services
At Lucent Advisory, we advise multinational companies and international businesses on transfer pricing advisory services across the full transfer pricing lifecycle, from transfer pricing strategy and policy design through to practical implementation and transfer pricing documentation and audit support, where strategy, operations, and execution come together.
Every multinational organization makes choices about where it operates, how risks are managed, and where value is created. Transfer pricing frameworks and policies translate these choices into a coherent, defensible, and sustainable allocation of profit across the group. Our services bring clarity to complexity by aligning transfer pricing outcomes with OECD guidelines and the way the business operates in practice, and support long-term, compliant growth across jurisdictions.
We work as a trusted partner to in-house tax and finance teams of multinational groups, as well as alongside law firms and other advisors, offering senior-level transfer pricing advisory that is thoughtful, pragmatic, and grounded in real-world execution.
Working with advisors
We regularly work alongside law firms and other professional advisors, as well as with international transfer pricing specialists, supporting their clients with specialist transfer pricing advisory services and local expertise in the Netherlands. In these collaborations, we act as a trusted partner, complementing existing relationships with focused, senior-level transfer pricing support.
Our role is to strengthen the overall advice provided to the client. We bring clarity to complex transfer pricing technical questions, ensure that positions are coherent and defensible, and help translate legal and tax considerations into practical transfer pricing policies and implementable outcomes.
We are mindful of the broader advisory context in which we operate. We work seamlessly alongside legal, tax, and finance advisors, aligning our input with the wider strategy and maintaining a consistent and well-founded transfer pricing position across jurisdictions.
Where needed, we support across the full transfer pricing lifecycle - from transfer pricing planning, structuring, and documentation (including Local File, Master File and economic benchmarking analyses) to implementation and tax authority audits or transfer pricing controversy discussions - always with a focus on quality, discretion, and long-term alignment.
Transfer Pricing Strategy & Design
We help clients shape OECD-aligned transfer pricing frameworks that support their business strategy - not constrain it.
Strategic transfer pricing advice
Designing robust, forward-looking transfer pricing policies that align with commercial objectives, risk appetite, and OECD guidelines, with alignment to local requirements in coordination with in-country advisors.Value chain analysis & business model optimization
Understanding where value is truly created across the group and translating that insight into defensible, OECD-aligned profit allocation and business models, both from an operational and transfer pricing perspective.Setting up new business models
Supporting reorganizations, centralization or decentralization strategies, IP structures, and changes in functional profiles with clear, well-reasoned transfer pricing frameworks aligned with OECD guidelines and coordinated with local advisors where relevant.
Our focus is on building models that are technically sound, operationally workable, and resilient over time.
Growth, Expansion & Transformation Support
Growth brings opportunity — and complexity. We guide clients through change with clarity and confidence.
Advising on global expansion
Supporting market entry, supply chain changes, and scaling strategies with transfer pricing solutions that anticipate tax, operational, and governance implications the group.Business transformations & restructurings
Assisting with cross-border reorganizations, shifts in value creation, and post-merger integration from a TP and economic perspective, working alongside legal and tax advisors in relevant jurisdictions.
We help clients make informed decisions early, reducing surprises later.
We help clients make confident decisions
Pillar Two & Global Minimum Tax
Guiding businesses through Pillar Two as part of an integrated, sustainable transfer pricing and business strategy.
We help clients navigate Pillar Two in a way that supports their broader business strategy and transfer pricing framework as part of a coherent, long-term approach aligned with OECD Pillar Two principles.
Our support includes:
· Assessing the impact of Pillar Two across the group
· Reviewing and sense-checking GloBE calculations
· Understanding how transfer pricing policies influence Pillar Two outcomes
· Advising on strategic responses and long-term design choices
· Supporting clear documentation and governance
Our focus is on building positions that are technically sound, operationally workable, and resilient over time.
Public Country-by-country reporting
European Public Country-by-Country Reporting (Public CbCR or PCbCR) introduces a new level of transparency, requiring multinational groups with qualifying activities in Europe to disclose selected financial and tax information on a country-by-country basis within the European Union.
We support clients in navigating European Public CbCR requirements, taking into account their existing CbCR and transfer pricing frameworks developed in the context of OECD BEPS Action 13. Beyond compliance, Public CbCR raises important questions around how a group’s value creation, profit allocation, and overall tax position are presented externally.
Our approach focuses on defining a clear and well-considered disclosure and publication strategy. This includes assessing which data to use, what it conveys, identifying potential sensitivities, and shaping a narrative that is coherent, defensible, and aligned with how the group wishes to be understood by external stakeholders.
We help clients present their position with clarity and consistency, anticipating how the information may be perceived by tax authorities, investors, and the wider public, while making thoughtful use of available options within the rules to manage complexity and avoid unnecessary disclosures and compliance burdens.
Transfer Pricing Documentation & Compliance
Clear documentation is not just about compliance. It is about telling a coherent, credible story.
Transfer pricing documentation
Preparation and coordination of high-quality Master Files, Local Files, and supporting analyses, including robust benchmarking studies, aligned with OECD guidelines, that reflect both technical soundness and business reality.Practical, audit-ready approach
Documentation that is consistent, defensible, and aligned with how the business actually operates - not generic or purely theoretical.
We combine deep expertise with AI-enabled delivery to enhance accuracy, consistency and efficiency.
We connect transfer pricing with how your business works
I start by listening carefully — to the business, the people behind it, and what truly matters and from there bring clarity to your transfer pricing position.
When uncertainty or disputes arise, we act as a steady guide through complex processes.
Advance Pricing Agreements (APAs)
Advising on unilateral, bilateral, and multilateral APA projects, from feasibility assessments and strategy to preparing the submission documentation and supporting engagement with tax authorities in the Netherlands and coordinating with advisors in other jurisdictions.Local Transfer Pricing Audits
We support clients during local transfer pricing audits, including in the Netherlands and in coordination with local advisors internationally, with a structured and thoughtful approach, helping them articulate their position clearly and consistently. We place strong value on maintaining a professional, open dialogue with tax authorities, understanding their perspective while firmly representing our clients’ positions and working towards balanced, sustainable outcomes.
Mutual Agreement Procedures (MAP)
Supporting clients in resolving double taxation through clear technical analysis, strong positioning, and constructive engagement with the relevant competent authorities, in coordination with advisors across jurisdictions where applicable.
Our approach is constructive, structured, and focused on achieving sustainable, well-reasoned outcomes.
Dispute Prevention & Resolution
Expertise meets guidance — so you can move forward with clarity
Lucent Advisory is intentionally boutique. Every engagement in complex transfer pricing matters is led with senior attention, strategic oversight, and a genuine commitment to partnership. We bring light where things feel complex, direction where choices feel uncertain, and confidence where decisions matter most.
Lucia Sahin
Founder of Lucent Advisory