Transfer Pricing

Strategic Transaction Planning & Structuring

 

Develop and implement tax efficient transfer pricing strategies, including review and analysis of:

  • arm's-length pricing principles and ranges

  • fundamental business components driving functions and risks of the parties

  • alternative pricing methods

  • determination of best pricing method

  • review and analysis of international tax rules and foreign tax rates, including the effects of applicable international tax treaties

  • work with operational management to understand commercial and inter-company motivational drivers

  • understanding local country transfer pricing regulations and the interrelation with global OECD guidelines

  • cost-benefit analysis of cost of compliance versus benefits of reduced transfer pricing adjustments and penalty exposure and risks

 

Transfer Pricing Studies

Review, analysis and preparation of transfer pricing studies, including:

  • identification, analysis and documentation of related party transactions

    • tangible goods, including manufacturing

    • related party services

      1. trading services

      2. back-office

      3. administrative support

    • financial transactions

      1. inter-company loans

    • intellectual property rights

      1. royalty agreements

      2. trademarks

      3. branding fees

      4. license fees

    • cost sharing & contribution arrangements

  • functional analysis

    • functions performed by parties

    • risk assumed by parties

  • evaluation of acceptable pricing methods

    • comparable uncontrolled price (CUP)

    • cost plus

    • profit split

    • resale price method

    • transactional net margin method

  • comparable analysis to unrelated parties

  • industry and economic analysis

  • corporate and regulatory environment overview

 

Transfer Pricing Risk Management and Reduction

 

Proactively manage transfer pricing policies, processes and compliance functions to minimize cost and exposure from tax audit assessments & risks, including:

  • manage transfer pricing audit process to minimize audit time

  • proactively work to resolve transfer pricing controversies at the field level in order to minimize risks and cost of potential litigation

  • cost/benefit analysis and implementation of strategies to minimize compliance cost while reducing risk exposures

  • mitigate risk of public claims of use of tax and transfer pricing strategies to unfairly disadvantage local programs and communities

Transfer Pricing Compliance

 

Develop, implement and perform compliance task and processes to minimize exposure to adjustments and penalties, including to accumulating and managing contemporaneous documentation in accordance with local country regulations and OECD guidelines, and local country:

  • transfer pricing statutory filings

  • transfer pricing studies

    • analysis of best pricing method for transaction

    • comparable analysis to uncontrolled parties and/or transactions

  • related party transaction statutory filings