MANUSA
Expertise
Automatic Door Solutions and Smart Access Systems
Industry
Industrial sector
Service
Transfer pricing
At a Glance:
New Transfer Pricing Policy
Strategic Impact of the Project
Definition and implementation of a new transfer pricing policy to strengthen the Group’s legal certainty, improve governance, and mitigate tax risks.
Key Elements
Functional and economic analysis, design of intragroup policies, and contractual arrangements to ensure consistency, traceability, and compliance.
Ayming's Role
Comprehensive support in the assessment, design, and implementation of the new policy, including economic analysis, supporting documentation, and contractual adjustments.
Strategic structuring of its intragroup operations
The Manusa Group is an industrial company with more than 50 years of experience, specializing in the design, manufacture, installation, and maintenance of automatic doors and smart access systems, with an international presence and a corporate structure that integrates various operating entities.
In an environment of increasing regulatory complexity and international expansion, the proper structuring of intragroup operations has become a key factor in ensuring financial consistency, legal certainty, and strategic alignment among the group’s various companies.
The Challenge
The Manusa Group needed to update and formalize its transfer pricing policy applicable to its main intragroup transactions, goods, services, and certain intangible assets, by adopting a practical approach aligned with the business’s actual operations.
The challenge was to define a consistent, robust, and defensible framework—one that not only complied with current regulations but was also ready for effective implementation within the group. This involved:
Formalize intra-group relationships in writing for internal approval
Board and Signatories
Avoid potential inconsistencies between companies or transactions
Minimize Tax Risks
The Solution
Support from Ayming
The project began with a detailed diagnostic assessment and functional analysis, identifying functions, assets, including intangible assets, and risks by entity and type of transaction.
Subsequently, an economic analysis was conducted, applying market-based methodologies such as CPM/TNMM on a case-by-case basis, to define compensation criteria in accordance with the arm’s-length principle and establish clear guidelines for their application.
The project concluded with the development of the 2024 Transfer Pricing Policy and the formalization of intra-group contracts, along with recommendations for their proper implementation.
Throughout the process, we provided close support to the CFO and his team until final validation and signing.
The best result
With clear and specific guidelines for each type of intragroup transaction.
Facilitating their formalization, documentary consistency, and internal traceability.
They ensure consistent application across entities and strengthen the group’s position in the event of a review.
The Impact
- Greater legal certainty and a more robust intra-group framework, reducing the risk of tax adjustments and potential inconsistencies among entities.
- Standardization of criteria and improved internal controls, strengthening governance and consistency in decision-making.
- Actionable deliverables, designed for immediate implementation and long-term sustainability, including technical documentation and formalized contracts.
We understand the challenges faced by industrial companies:
Complexity in the Value Chain
We accurately determine the value that each company brings to the process.
Compliance with the “Arm's Length” Principle
We make sure to justify the transaction prices in relation to market prices.
Double Taxation and Conflicts Between Jurisdictions
We prevent different countries from taxing you on the same income.
