Transfer Pricing

As your business expands its global footprint, multiple tax authorities want “their share” of your income. To protect against multiple fiscal authorities claiming taxes on the same revenues, related-party cross-border transactions should have the protection of comprehensive, contemporaneous documentation demonstrating that the terms of the transaction are at arm’s length.

Our cohesive international tax and transfer pricing solutions provide practical guidance for the required documentation and economic analysis to achieve this protection.

Specifically, we can help you identify the optimal tax structure, manage your worldwide tax exposure and improve the after-tax results of your business in the following ways.

Hands-on attention. We offer direct access to highly qualified specialists with decades of cross-border transactional experience.

Integrated cross-functional approach. We coordinate transfer pricing projects with our international tax, domestic tax and state and local tax professionals to optimize the allocation of income between jurisdictions, avoid pitfalls, and meet the reporting requirements.

Broad industry expertise. Our advisors employ a highly nuanced approach to guiding clients across an array of industries, including consumer products, life sciences, technology, digital assets (fintech/crypto) and manufacturing.

Experience addressing tax authority inquiries. Our advisors draw from valuable insights gained through negotiating extensively with the Internal Revenue Service and supporting local advisers negotiating with tax authorities in foreign jurisdictions.

“Boots on the ground” presence. Our membership with DFK International, a global association of independent accounting firms, gives us a clear view of transactions wherever you conduct business.

Ignoring transfer pricing obligations can result in tax adjustments, protracted disputes with tax authorities, double taxation, penalties and interest charges. To avoid costly consequences, taxpayers need a transfer pricing approach that complies with both U.S. and local country transfer pricing rules. In addition, the OECD’s BEPS initiative prescribes more stringent requirements for the determination of pricing of intercompany transactions, among other issues.

Contact us or a member of the Transfer Pricing Services team to discuss ways to become compliant with the applicable transfer pricing rules, ensuring seamless transactions and optimized tax benefits.

Our integrated tax services ensure that your transfer pricing compliance needs are met, so you can spend more time pushing beyond the borders of possibility and benefit from the following:

• Transfer pricing studies, documentation of related-party transactions and competent authority relief assistance
• Establishing benchmarks for the pricing of related-party transactions
• Assistance with tax dispute appeals and resolutions
• Structuring of transactions to enhance the benefits of intangible and financial transactions
• Strategic planning initiatives to facilitate flexibility and cooperation between the key global decision-makers of the business
• Assist startups in establishing transfer pricing policies, procedures and documentation
• Controls and systems for setting, monitoring and testing the prices of intercompany transactions
• Valuation of intangible and other assets for tax, legal and business purposes
• Identification of state and local tax exposure and tax planning opportunities
• Assessment of procedures and systems to support compliance with the Organisation for Economic Co-operation and Development’s (OECD) base-erosion and profit-shifting (BEPS) initiatives and country-by-country compliance requirements
• FIN 48 analysis relating to transfer pricing matters for recognition of tax benefits and recording of reserves for financial statements
• Documenting the substance of holding companies and other group entities to provide protection from various general amount avoidance regimes and to evidence a sound economic business purpose for the structure