
Transfer Pricing · Nicosia, Cyprus
Certainty in every controlled transaction.
ADDVALUE helps multinational groups price, document and defend their intercompany transactions in line with OECD Transfer Pricing Guidelines and the Transfer Pricing rules of each jurisdiction involved.
What we do
Specialist support across the compliance lifecycle

Transfer pricing risk diagnostics
We map your controlled transactions, quantify your exposure if they are challenged, and identify the documentation required.
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Documentation and compliance
Local File, Master File and Summary Information Table, prepared to be defended rather than merely filed.
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Benchmarking and economic analysis
Comparable searches with a full screening trail — every acceptance and rejection documented and reasoned.
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Intra-group financing and treasury
Loans, cash pooling and guarantees under Chapter X of the OECD TP Guidelines.
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Intangibles and DEMPE
Royalties, licensing and IP transfers — including the interaction with the Cyprus IP Box.
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Operating model and policy design
Intercompany operating models and the policy that allocates profit across the group, including business restructurings.
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Audit defence and dispute resolution
Support from the first information request through to MAP and arbitration.
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Advance Pricing Agreements
Certainty on specified transactions for a defined period, unilateral, bilateral or multilateral.
Learn moreWhy ADDVALUE
A boutique firm, entirely focused on transfer pricing
That focus is what lets us go deeper than a general practice — and stay ahead of a fast-moving regulatory landscape, so your positions hold up when it matters.
Led by Christos Tziallas — BSc, ACCA, ADIT, and lecturer in transfer pricing at UNIC Globaltraining.


Our mission
To help clients manage their transfer pricing risks and build policies that maximise company value — while staying fully compliant with the law.
Our vision
To deliver the best client experience with top-quality execution that supports our clients’ growth.
How we work
From first review to audit-ready
Assess
Map your related-party transactions and score the transfer pricing risk in each.
Benchmark
Build the arm’s length range through comparability analysis and selection of the most appropriate method.
Document
Prepare Master File, Local File and CbC Report to OECD and applicable local requirements.
Defend
Support the position through audit and dispute, from the first information request to resolution.
Training
Transfer pricing seminars
Practical, module-based training that gives your team the concepts and techniques to reach full compliance with the new TP regulations.
Transfer Pricing
Arm’s-length principle · comparability · TP methods · documentation.
moreIntra-group services
Pricing & documenting intra-group services, incl. low-value-adding.
moreIntra-group intangibles
Transactions involving intangibles — valuation, ownership, documentation.
moreIntra-group financial transactions
Loans, guarantees and cash-pooling under the arm’s-length standard.
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