TPnavigator
Transfer Pricing Advisory
Expert transfer pricing guidance for multinationals, tax professionals and accounting professionals — grounded in more than three decades of experience at the Dutch Tax Authorities (including as Head of APA Team and as Competent Authority), Big 4, independent advisory, and senior in-house roles.
What we do
TPnavigator offers focused transfer pricing support across the full TP lifecycle — from strategy and policy design through documentation, operational implementation and controversy management.
Design and documentation of intercompany pricing policies aligned with your business model, value chain and risk profile — audit-proof and OECD-compliant.
Comprehensive, defensible TP documentation tailored to your operations and jurisdiction — from Master File and Local File to benchmarking studies and CbCR.
Expert guidance through tax authority negotiations, audit defence, Advance Pricing Agreements and Mutual Agreement Procedures — leveraging deep insight into authority thinking from both sides of the table.
Implementation of TP policies in day-to-day operations — connecting TP strategy with finance, procurement, and ERP systems to achieve consistent, real-time compliance.
Valuation and structuring of intellectual property and intangible assets — including IP migrations, licensing models, cost-sharing arrangements and royalty benchmarks.
Specialised TP expertise on demand for tax advisors, law firms and accounting practices — supporting complex mandates, second opinions, transaction reviews and client-facing deliverables.
How we engage
TPnavigator works across a spectrum of engagement models — from focused project support to long-term advisory relationships. Every arrangement is built around what genuinely serves the client's needs.
Multinationals and in-house tax teams across all sectors and sizes can engage TPnavigator for focused support or a broader ongoing relationship.
Ongoing senior-level TP counsel alongside your in-house team — available for brainstorming on strategic questions, board-level briefings, audit responses and complex decisions as they arise.
Working as part of your finance or tax team for a defined period — handling specific deliverables, building in-house capability, or covering resource gaps during busy periods.
Defined scope, fixed timeline — for transactions, restructurings, APA applications, audit defence, documentation programmes or TP health checks.
Targeted sessions for finance, legal and tax teams — from TP fundamentals for non-specialists to advanced workshops on controversy, APAs and BEPS/Pillar Two implications.
Tax advisors, law firms and accounting practices can draw on TPnavigator's specialist depth for client mandates where dedicated TP expertise makes the difference.
Supplementing your team's capacity on TP-intensive mandates — delivering client-ready work product under your banner or as a named specialist.
Independent review of TP positions, documentation packages or litigation arguments — adding credibility and catching issues before they reach a tax authority.
Structured coaching for your TP practitioners and generalist advisors — building internal capability on complex topics such as APA/MAP procedures, intangibles, profit splits, controversy management and OECD developments.
Bespoke training for advisory teams on TP fundamentals, recent OECD guidance, Pillar Two interactions and specific transaction types — drawing on direct regulatory experience.
Engagements are entirely flexible — discuss your situation and we will structure an arrangement that fits. Start a conversation.
How we work
Transfer pricing can be technically demanding — but good advice should be clear and actionable. TPnavigator brings senior-level expertise without the overhead of a large firm, offering direct access to an advisor who has operated across all sides of the TP spectrum: tax authority, Big 4, in-house and independent advisory.
Every engagement is tailored to your organisation's specific situation, risk appetite and commercial objectives. The goal is always a workable, defensible outcome — not a perfect theoretical model that falls apart under scrutiny.
"Transfer pricing is where tax, economics, and business strategy intersect. The best solutions navigate all three — simultaneously."— Richard Slimmen
Sector experience includes:
30+ years of hands-on TP experience across multinationals, tax authorities and advisory firms.
Solutions that work in practice — commercially sound, technically defensible, operationally feasible.
Inventive problem-solving for complex, non-standard intercompany structures and challenging fact patterns.
You work with Richard directly — no delegation to junior staff, no layers of overhead.
Frequently asked
Transfer pricing refers to the prices set for transactions between related entities within a multinational group — covering goods, services, royalties, loans and more. Tax authorities worldwide scrutinise these prices to ensure profits are allocated fairly across jurisdictions in line with the arm's length principle.
You likely need specialist advice when your group (or your client) faces a transfer pricing audit or dispute, is preparing or renewing an Advance Pricing Agreement (APA), is restructuring operations or supply chains, needs to put robust documentation in place, or is navigating the implications of BEPS or Pillar Two. Early advice typically costs far less than resolving problems after the fact.
Yes. As soon as a business has cross-border transactions with a related party — even at relatively modest volumes — the arm's length rules apply. Tax authorities worldwide have increasingly broadened their focus to include SMEs. Thinking ahead about straightforward documentation and a defensible pricing policy often prevents costly disputes.
A pragmatic approach and a careful cost-benefit analysis are highly valued in this context. An appropriate risk assessment is essential. TPnavigator also works with SMEs that have no need for an unnecessarily elaborate engagement, but do need sound, practical advice.
TPnavigator covers the full transfer pricing spectrum:
At a large firm, senior partners typically originate work and then pass execution to more junior staff. At TPnavigator, Richard Slimmen personally handles every engagement from start to finish — there is no delegation, no handover, and no overhead charge for layers of management.
This means clients receive 30+ years of expertise applied directly to their situation, with faster turnaround and a genuinely personal relationship. Engagements are priced to reflect the actual work required, not the billing structure of a large organisation. For complex, high-stakes matters where the quality of the individual advisor matters most, this difference is significant.
Yes, and this is a deliberate choice. Many firms serve clients where relatively straightforward transfer pricing matters can be handled internally. Sometimes, however, more complex issues arise that require deeper TP expertise than is available in-house. In those cases, TPnavigator acts as a specialist — visibly or in the background, depending on what the contracting firm prefers.
The focus is on working closely with the existing client team, making optimal use of the firm's client knowledge and TPnavigator's deep TP expertise.
TPnavigator is explicitly not a competitor but an extension. TPnavigator's work is complementary to the contracting firm's own work. This ensures the underlying client is served optimally and prevents such client from having to turn to other advisors when more complex TP issues arise.
In practice, clients greatly appreciate it when their trusted adviser puts the client's interests first and brings in additional expertise where needed. When TPnavigator's specific expertise is no longer required, TPnavigator's involvement will simply cease or be phased out in concert with the client.
It varies considerably by situation. A first opinion, a quick TP health check or a basic policy for an SME is quite different from a full APA engagement for a multinational. TPnavigator works on a project, retainer or interim basis and aligns the approach and budget with the scale and complexity of the assignment.
Relative to the expertise and experience delivered, TPnavigator's fees are highly competitive. A no-obligation conversation will quickly clarify what your specific situation requires.
Yes. In addition to ongoing advisory relationships, Richard is available for interim transfer pricing roles — embedded within an in-house tax team for a defined period — as well as focused project engagements, expert-witness assignments, and co-sourcing arrangements where a company or firm needs senior TP capacity without a permanent hire.
These engagements are fully flexible in scope and duration, and can be structured as a day rate, project fee or retainer depending on what best fits the client's situation. Recruiters and in-house hiring managers are welcome to reach out directly to discuss availability and fit.
The short answer is: as early as possible. Prevention is generally better than cure. A risk analysis — ideally carried out before any audit is initiated — allows risks to be identified and managed proactively, reducing the likelihood of disputes if an audit does arise. This is where TPnavigator can add significant value.
Once an audit is underway or has been announced, there is no longer room to manage risks proactively. The focus must then be entirely on defending the existing position and preventing adjustments. However, given TPnavigator's extensive experience with complex transfer pricing disputes arising from tax audits, TPnavigator can often still make a meaningful difference in achieving reasonable outcomes.
An APA is a binding agreement between a taxpayer and one or more tax authorities that confirms the transfer pricing methodology for future intercompany transactions, providing certainty and eliminating dispute risk. Bilateral and multilateral APAs involve two or more tax authorities and offer the most comprehensive protection against double taxation.
The Netherlands has a well-developed APA programme. Richard Slimmen spent seventeen years at the Dutch Tax Authorities, heading its APA team and serving as Competent Authority in bilateral and multilateral procedures. That firsthand understanding of how the authorities assess APA requests and conduct negotiations is a distinctive advantage for clients pursuing (Dutch) APAs.
Absolutely. Such audits have increased significantly in recent years, both in number and depth. Proper guidance throughout the process is essential to reach a satisfactory resolution. It often only becomes clear during an ongoing audit that specific transfer pricing issues are being examined — and earlier questions and answers can suddenly take on a different significance.
It is therefore important to form a clear picture of potential TP discussion points as early as possible and to monitor these actively throughout the audit process. TPnavigator can assist in developing an appropriate defence strategy, assessing the potential impact of questions and answers, and actively supporting negotiations with the tax authorities to reach a workable resolution.
A tax audit is a complex process — not merely a technical discussion. The right combination of substantive expertise and process awareness is needed to achieve the best results. TPnavigator's extensive experience with the Dutch Tax Authorities often helps identify and develop the right lines of resolution.
Yes. The OECD's BEPS project and the introduction of Pillar Two's global minimum tax rules have significantly increased the complexity of intercompany pricing for multinational groups. Transfer pricing policies that were defensible before may need to be reconsidered in light of the 15% global minimum tax, substance requirements and the interaction between Pillar Two and existing APA coverage.
TPnavigator advises on BEPS action plan implementation, transfer pricing documentation aligned with BEPS standards, and the transfer pricing implications of Pillar Two — including identifying risks and opportunities in your current intercompany arrangements before tax authorities raise them.
Richard Slimmen has worked across more than 20 jurisdictions throughout his career, with deep experience in the Netherlands, broader Europe, and key trading partners in Asia, the Americas and the Middle East. His work spans bilateral and multilateral APA and MAP procedures involving multiple competent authorities simultaneously.
In terms of sectors, TPnavigator has experience across manufacturing & supply chain, chemicals & plastics, technology & software, automotive, IP-rich businesses and financial services — with a particular strength in complex, non-standard intercompany structures where standard benchmarking approaches are insufficient.
Former Head of APA Team · Dutch Tax Authorities
Founder of TPnavigator and one of the Netherlands' most experienced transfer pricing practitioners — with a career spanning tax administration, ministry, Big 4, independent advisory and senior in-house leadership.
Richard Slimmen
Founder, TPnavigator
Senior Transfer Pricing Advisor & Independent Consultant
Richard Slimmen brings over 30 years of transfer pricing expertise to every engagement. His career is unique in its breadth: starting at the Dutch Tax Authorities where he headed the APA practice and served as Competent Authority, through senior advisory roles at a Big 4 firm and founding and leading specialist TP boutiques, to in-house leadership as Global Head of Transfer Pricing at complex multinationals.
He also lectured transfer pricing for many years at the International LLM Programme at Leiden University.
Full-scope transfer pricing advisory to multinationals and tax consultancies. TP strategy, APA/MAP, audit defence, documentation and governance — directly delivered by a senior practitioner.
Over 14 years co-founding and leading independent transfer pricing boutiques (Quantera Global, Coperitas, TPA). Built and managed client portfolios spanning manufacturing, chemicals, technology and IP-rich multinationals across 20+ jurisdictions. Developed deep expertise in full-lifecycle TP: from policy design and documentation to operational implementation and dispute resolution.
Transfer Pricing Director, co-leading a 25-person TP practice. Advised multinationals on IP structures, supply chain reorganisations, financing arrangements and cross-border business restructurings. Negotiated unilateral and bilateral APAs and developed audit defence strategies for complex, multi-jurisdictional fact patterns.
Senior Policy Advisor for international fiscal affairs. Coordinated Dutch transfer pricing policy, represented the Netherlands in bilateral and multilateral APA negotiations, and contributed actively to OECD working groups on transfer pricing — providing direct insight into how international TP standards are shaped and applied.
Seventeen years at the Dutch Tax Authorities, building and heading the APA practice. Senior member of the Dutch Coordination Group on Transfer Pricing. Served as Competent Authority in bilateral and multilateral APA and MAP procedures — conducting intergovernmental negotiations on behalf of the Netherlands and working directly with the OECD and treaty partners. This unique vantage point from within a tax authority — understanding how inspectors assess risk, evaluate substance and approach negotiations — remains a defining feature of the advisory work at TPnavigator.
Availability
Richard is available for independent advisory engagements, interim transfer pricing roles, expert-witness assignments and co-sourcing arrangements — directly accessible to corporates, in-house tax teams, and tax & accounting firms across the Netherlands and internationally.
Professional memberships
Get in touch
Whether you need strategic advice, documentation support, help with a tax authority dispute, or specialist TP expertise for a client engagement — reach out for an initial conversation.
