International transfer pricing is one of our primary practice areas. Our services in this area include the following.

Controversy

Much of our work relates to transfer pricing controversy. We are routinely called upon by both taxpayers, tax authorities, and other parties to assist as expert witnesses in tax litigation and bankruptcy litigation. We negotiate with governments on behalf of our clients. Our position as industry thought leaders means that large law firms seek us out to assist them, and their clients, in managing some of the largest transfer pricing controversies. We maintain good relationships tax authorities, and have assisted certain tax authorities in the development of policy positions that allow for “win-win” settlements of large cases and issue types.

Design

We are routinely called upon to assist in designing and pricing supply chain, intangible property, and other intercompany transaction structures. Our efforts in this area include the development of effective and reliable methods for valuing entity conversions, pricing contractual features, pricing exploitation and research rights, modeling the realistically available alternatives of the parties to business restructurings, pricing guarantee fees, rating and pricing intercompany debt, debt versus equity characterization, developing profit splitting structures, and numerous other economic analyses. Importantly, our planning efforts are always conducted with the potential for downstream controversy risk in mind. Our significant controversy experience allows us to develop defensible transfer pricing structures that avoid tax authority scrutiny.

Co-Development

In some cases, our clients wish to use us as a “second set of eyes” when implementing large global planning structures. We are generally able to model, assess the tax impact, and evaluate the risks, of planning positions relating to complex global supply chain structures much more quickly, and we believe more thoughtfully, than our Big 4 competitors. We also co-develop valuation models for our clients, as well as cost-effective masterfile documentation.

Documentation

Our documentation efforts generally center on documenting structures that we have assisted in designing. However, we also provide initial documentation for clients’ existing transactions, as well as documentation updates for those transactions. Our approach to documentation is highly cost effective.