Transfer Pricing Tax Services for Multinational Businesses

Effective transfer pricing documentation can support your company’s intercompany arrangements with:

An in-depth discussion of the functions performed and risks borne by the respective entities
An economic study to demonstrate that your company acted in accordance with the arm’s length standard

We can assist you in preparing accuracy-related penalty protection documentation; OECD reports, including master files and local files; and foreign transfer pricing documentation through:

BEPS country-by-country reporting consulting and compliance
Benchmarking
Financial services benchmarking for cash pooling, loans, and guarantees
Intangible property valuations and related strategies, including cost sharing
Cost allocations for organizations in all industries, including tax-exempt organizations

Start Strategic Planning

Transfer pricing planning can take place during any stage of a company’s life cycle.

Whether your company is expanding internationally, enhancing your international supply chain, or migrating intangible property, effective transfer pricing planning is critical to reduce your effective tax rate while remaining in compliance with tax jurisdictions around the world.

We have deep experience in transfer pricing valuations of intangible property, economic benchmarking, and tax planning strategies in response to various compliance and regulatory changes, including:

Risk and opportunity assessment
Multistate transfer pricing planning
Group structuring prior to international expansion, acquisition, or restructuring
Policy design and implementation
Design of arm’s length interest rate benchmarking for cash pooling, loans, and guarantees
Intangible property valuations and related strategies, including cost sharing
Cost allocations for organizations in all industries, including tax-exempt organizations

Proactive planning can also help set up financing arrangements like intercompany loans and cash pools to meet transfer pricing requirements.

Assess Provisions

Reserving for uncertain tax positions related to transfer pricing can have a material impact to your company, particularly when a transfer of intangible property occurs.

Transfer pricing should also be a consideration during the tax provision when your company has intercompany arrangements related to base erosion and anti-abuse tax (BEAT) and foreign derived intangible income (FDII).

We can assist in determining if a reserve is needed for your company’s transfer pricing policies and what the magnitude of that reserve should be through:

Analysis of uncertain tax positions
Review of interest rate benchmarking for cash pooling, loans, and guarantees
Intangible property valuations and related strategies, including cost sharing
Cost allocations for organizations in all industries, including tax-exempt organizations

Perform Due Diligence

Transfer pricing due diligence is often overlooked in the context of M&As. Often the target may be unfamiliar with transfer pricing and the risk posed due to a lack of transfer pricing policies and documentation. This is particularly true of companies early in their life cycle.

We can help you:

Identify transfer pricing risks embedded in the target
Estimate the magnitude and materiality of that risk

Address Tax Controversy

Tax authorities around the world have increased their audit efforts in recent years. No matter how tight your transfer pricing policies and documentation may seem, there’s a possibility that a tax authority will assert adjustments and potentially add penalties. We have deep experience in assisting clients to navigate transfer pricing audits.

We can provide supplementary economic studies and documentation while assisting you in responding to the tax authorities’ questions and information document requests with:

Tax controversy and dispute resolution
Advance pricing agreements

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