Your specialized transfer pricing advisor
Your specialized transfer pricing advisor
Specialized Firm
QCG Transfer Pricing is a specialized practice dedicated to providing holistic, strategic solutions that turn your transfer pricing structure into a true value driver. Our solutions go beyond compliance. From planning optimal value chain structures, benchmarking and all compliance documentation to controversy support and defense, we can assist you in every step of your transfer pricing analysis.
Our goal is to transform you transfer pricing strategy into a true value driver for your organization.
Technical excellence
Every solution we deliver is built on technical precision, guaranteeing optimal results, minimizing risk and maximizing benefits in every transaction.
Innovation at our core
We integrate cutting-edge tax technology to streamline compliance and drive efficiency. Our proprietary Transfer Pricing Diligent® platform, developed by transfer pricing experts, enhances documentation accuracy and simplifies complex analyses. We also leverage econometric models and automation to optimize the analysis process.
Multidisciplinary practice
Our team of accountants, economists, finance professionals, and legal experts delivers industry-specific solutions tailored to your business. This integrated approach ensures comprehensive, innovative, and defensible transfer pricing strategies to satisfy the specific needs of every client.
Publications
The Business Rationale for Intra-Group Services: QCG’s Comments to the OECD on Chapter VII
On 1 June 2026 the OECD released a public consultation document on proposed revisions to Chapter VII of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, covering special considerations for intra-group services. The stated objective of the work is to align the guidance on intra-group services with the
Limits on Transfer Pricing Adjustments and Risk Allocation: The Nissan Chile v. SII Case
Following the resolution issued by the Second Tax and Customs Court of the Metropolitan Region in deciding the claim filed under the general claims procedure established in that jurisdiction’s Tax Code — whereby Chile’s Internal Revenue Service (SII) assessed Nissan Chile a tax amounting to $5,774,515,810, surcharges included — it
Business Purpose, Economic Substance, and Transfer Pricing: The New Trilogy of Mexican Tax Audits
In multinational groups, the question comes up often: why is a related-party transaction challenged when there is a contract, a CFDI electronic invoice, documented payment, and a transfer pricing study?
The answer is direct: tax audits no longer look only at form. Today, Mexico’s tax authority (the SAT) examines whether the transaction had a business purpose, whether it had economic substance, and whether its consideration was set in line with the arm’s length principle. The analysis is no longer documentary — it is structural.
25 years
Of continuous transfer pricing experience
15,000 +
Successfully delivered engagements
10 years
Of specialized industry forums
7 times
Nominated as Best Transfer Pricing firm by ITR
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