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TRANSFER PRICING

Understanding the movement of expenses within an organization.

Transfer Pricing: Section 482

In addition to being an international tax issue, transfer pricing is becoming a problem between states in the US also. When one division (or subsidiary) of a company transfers goods or services to another division (or subsidiary) within their company, these goods and services are transferred at a certain price. If these two divisions (or subsidiaries) are in different countries, the price at which goods and services are transferred will impact the amount of taxable income in each country. Because this situation can result in shifting net income and profit, as well as taxes due between countries, many countries have adopted tax policies to review and assess penalties if it appears a company has attempted to transfer costs to tax havens (countries with lower tax rates). Today, most countries have adopted tax laws utilizing the arm’s length principle defined by the OEDC (Organization for Economic Co-operation and Development ).

Acena Consulting can help companies to complete a Transfer Pricing study to analyze their inter-company transactions and pricing policies. Our team of economists and former “Big Four” professionals bring a wealth of experience to benefit our clients.

Transfer Pricing Studies & Support

Let us help you to analyze and assess your transfer pricing issues

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

Service Description

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Testimonials

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