Transfer Pricing

Companies with related-party transactions that cross tax boundaries (whether country, state, or local) are confronted with increasing levels of scrutiny from taxing authorities and are burdened with an increasing number of transfer pricing–related compliance requirements. At the same time, these companies face pressures to reduce their global effective tax rate, improve their earnings per share, and move cash where it’s needed for operations.

Failure to have appropriate transfer pricing policies and procedures in place—and the required documentation to support them—could lead to protracted and costly transfer pricing audits that can result in significant additional tax liabilities and accompanying penalties.

Our Approach

Wherever your business is in its life cycle, from start-up to mature public company, our goal is to help you establish, implement, document, and (if necessary) defend a transfer pricing policy that reflects a clear understanding of your company’s industry, business operations, and overall strategic objectives. We understand that one size doesn’t fit all when it comes to transfer pricing. That’s why we tailor our services to work within your company’s risk profile and exposure tolerance.

Our membership in Praxity, AISBL—a global alliance of independent accounting firms that connects us with the expertise of like-minded firms across the globe—allows us to carefully consider all sides of virtually any transfer pricing situation by enlisting local country transfer pricing expertise whenever the need arises.

Services We Offer

  • Risk and opportunity assessments
  • Group structuring (prior to international expansion, acquisition, or restructuring)
  • Policy design and implementation
  • Intangible property valuations and related strategies (including cost sharing)
  • Benchmarking
  • Contemporaneous documentation (single-country or master and local files)
  • BEPS country-by-country reporting consulting and compliance
  • Cost allocations for organizations in all industries, including tax-exempt organizations
  • Multistate transfer pricing planning
  • Analysis of uncertain tax positions
  • Tax controversy and dispute resolution
  • Advance pricing agreements

Contact us to learn more about our transfer pricing services and how we can help your organization reduce its global exposure while remaining in compliance.

Insights


Article
Why and how international companies should prepare for coming changes to the definition of company presence due to the base erosion and profit shifting package.

Alert
The IRS issued final country-by-country (CbC) reporting regulations for US-based multinational enterprise groups, a product of the OECD and G20 countries’ base erosion and profit shifting project.

Article
Two of the IRS’s latest IPUs serve as useful reminders to taxpayers of some basic tenets of US transfer pricing rules under IRC Section 482.

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