Transfer Pricing2018-05-10T17:23:33+00:00

Transfer Pricing Services

With ever-increasing pressures and a constantly changing tax landscape, many companies are shifting their focus to actively monitor their transfer pricing positions.

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.

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PLANNING AND IMPLEMENTATION

INTANGIBLE PROPERTY

ETR management via cost-sharing, licensing agreements, sales, and transfers of all types of intangibles.

TANGIBLE PROPERTY

Price goods along the supply chain to optimize income tax, customs, operational performance.

TRANSFER PRICING DESIGN AND DEVELOPMENT

Design intercompany pricing to integrate seamlessly with the client’s commercial and operational objectives.

SERVICES

Structure management services arrangements to enhance cash flow; credit and ETR management.

FINANCING

Price simple loans, hybrid financial instruments, guarantees, factoring and insurance products.

OPERATIONAL TRANSFER PRICING

Develop framework for unit intercompany pricing of products to more efficiently achieve TP goals.

INTERIM TESTING

Conduct interim testing on a periodic basis to avoid material year-end TP adjustments.

COMPLIANCE AND DISPUTE RESOLUTION

§6662 U.S. DOCUMENTATION

Assist clients in analyzing and documenting transfer prices in accordance with U.S. regulations.

AUDIT DEFENSE

Develop TP audit defense strategy; represent taxpayer at tax audit meetings, negotiate resolutions.

COUNTRY-BY-COUNTRY REPORTING

Assist clients in preparing and gathering the necessary information for OECD country-by-country reporting.

COMPETENT AUTHORITY

In the event of double taxation arising from a tax audit, prepare taxpayer’s transfer pricing Competent Authority resolution.

MASTER FILE / LOCAL FILE

Preparing master file and local file documentation to meet with OECD guidance and local country regulations.

LITIGATION AND APPEALS

Work with clients and their legal advisors to provide analytical support to achieve acceptable outcomes.

ADVANCE PRICING AGREEMENTS

Design pricing models, file APA request, negotiate and agree to terms with U.S. and foreign tax authorities.

OTHER TRANSFER PRICING SERVICES

BANKRUPTCY

We perform transfer pricing analysis of claims in bankruptcy litigation, and have acted as experts in several bankruptcy matters.

NON-PROFIT

We perform studies to determine the arm’s length prices for transactions occurring between commonly controlled non-profit and for-profit companies. 

STATE TRANSFER PRICING

We perform transfer pricing planning, documentation, and controversy support for state transfer pricing matters. 

REITs

We perform studies determining the arm’s length pricing for payments made by taxable REIT subsidiaries to parent REITs for rent, interest and/or similar items.

MINORITY INTERESTS

Occasionally, intercompany transactions disadvantage a minority interest. We have analyzed transfer pricing arrangements from both the perspective of a parent company, and the minority interest. We have been called upon to settle disputes as part of negotiations surrounding these issues. 

NET SMELTER ROYALTIES AND MINING-RELATED CLAIMS

In the mining sector, it is not uncommon for royalties to be paid to a licensor of a mining claim, based upon the commercial value of the output of a mine. We have assisted licensors, and licensees in examining whether intercompany transfer pricing that affects the calculation of the royalty payments to the unrelated licensor are arm’s length.