Transfer Pricing

Through negotiation with U.S. and foreign governments, we’ll structure advance pricing agreements for transfer pricing policies over a multiyear period. By attaining government buy-in, we’ll significantly reduce risk on both sides of the transaction. We’ll help you lessen the annual documentation burden and reduce the risk of transfer pricing audits, adjustments, double tax, and penalties. APAs also reduce risk for both past and future years with a potential “roll back” agreement.

Our studies include an outline of company facts and history, market and industry benchmarking, definition of related-party transactions, and a detailed functional analysis of relevant entities. We can prepare documentation to comply with U.S. Section 482 Regulations, OECD Transfer Pricing Guidelines, and other countries’ rules. We’ll help you demonstrate past transactions were performed at arm’s length and comply with mandatory requirements from various countries. And we’ll help you mitigate penalty risk in the United States and prepare for potential tax audits.

With new Base Erosion and Profit Shifting (BEPS) reporting requirements, it's more important than ever that multinational companies efficiently collect, validate, and standardize their data. Our team of transfer pricing experts can support you with the implementation of enterprise systems and processes that help you keep up with local tax rates and transfer pricing rules, achieve compliance, mitigate risk, and forecast results.

When it comes to transfer pricing audit and defense, our global team has experience supporting audit defense at all levels. If you have a full transfer pricing report prepared and ready for submission to the IRS, our team will step in and answer any questions posed by the IRS as they review your report. Alternatively, if you don’t have a transfer pricing report prepared for the IRS, we can provide that analysis on a short-term basis and then answer any follow-up questions.

Instead of only documenting the past, we’ll proactively calibrate pricing for future transactions. This prospective analysis can easily serve as the basis for future documentation. We’ll help you establish your arm’s-length results for subsequent tax years, considering operational changes, while also minimizing the risk of tax penalties and optimizing tax planning. We can also help restructure your intercompany pricing policies and architecture and design global transfer pricing policies to simplify your transfer pricing administration.