Transfer Pricing Studies & Support
In addition to being an international tax issue, transfer pricing is becoming a larger issues between states in the US. Demonstrating arms-length transactions between related entities either domestic or internationally is critical to successfully defending your company against a state of federal tax audit.
Our team of international tax experts include former "Big 8" partners who have worked with both Fortune 100 companies and small growing organizations beginning to operate in a global market.
Today, more than 60 governments have implemented transfer pricing rules most of which follow the OECD definition of an arms length transaction (notable exceptions include Brazil and Kazakhstan). Our services include:
- IRS and state audit support in the event of an audit
- Unilateral and bilateral Advanced Pricing Agreements
- Federal and state pricing documentation
- Cost sharing agreements between related parties
- Tax Treaty review and analysis
- Transfer Pricing Strategy consulting
- FIN48 support & analysis
- Intangible valuations and analysis
- Global documentation design and development
- Assistance with best practices development and implementation