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
ETR management via cost-sharing, licensing agreements, sales, and transfers of all types of intangibles.
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.
Structure management services arrangements to enhance cash flow; credit and ETR management.
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.
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.
Develop TP audit defense strategy; represent taxpayer at tax audit meetings, negotiate resolutions.
Assist clients in preparing and gathering the necessary information for OECD country-by-country reporting.
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
We perform transfer pricing analysis of claims in bankruptcy litigation, and have acted as experts in several bankruptcy matters.
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.
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.
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.