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Transfer pricing has become the most important international tax issue facing multinational corporations. Given the global nature of business today, it is easy to understand why. Corporations are increasingly crossing national borders to reach new customers or to lower the cost of doing business. This increase in cross-border transactions has been accompanied by an attendant increase in examination of transfer pricing by the IRS and other global tax authorities.

Our transfer pricing & consulting services are centered around eight primary solutions:

• Business & IP Valuation
• U.S. Penalty Protection Documentation
• Advance Pricing Agreements
• Strategic Planning and Business Restructuring
• Litigation Support
• OECD Masterfile Studies
• Tax Controversies
• Cost Sharing Arrangements

Any business entity operating in more than one country likely has intercompany transactions involving the exchange of tangible property, intangible property or services. The U.S. transfer pricing regulations, under Section 482 of the Internal Revenue Code, require that intercompany transactions be priced under the same terms that would have existed had the transactions taken place between unrelated entities. Similar regulations now exist in virtually every developed nation around the world.

Where firms do not have studies, the cost to defend against a transfer pricing adjustment can be high, and the firm faces the risk of additional penalties in some locations, such as the United States . Even in the best case scenarios, complying with transfer pricing regulations and handling transfer pricing challenges can tie up important firm resources and cost far more than having a transfer pricing study done in advance of an examination.

How We Can Help

Corporations are facing more frequent examinations in non-US locations, as tax authorities throughout the world have placed more emphasis on transfer pricing. This has resulted in larger and more frequent adjustments to transfer pricing as well as double taxation. Our professionals have impressive broad-based experience that provides them with the background and expertise to address all transfer pricing issues faced by multinational corporations and professional service providers. Regardless of whether you prefer to completely outsource your transfer pricing needs, or are simply looking for support to augment your current transfer pricing capabilities, we are here to help you.