Avoid risk and optimize your tax position
Transfer pricing is an increasing area of focus for tax authorities around the globe, with strict rules enforced in virtually every country. If regulators determine you have insufficient documentation to support your transfer pricing model, your business could face fines or other penalties. Compliance can be overwhelming and complex for anyone –– that’s where our transfer pricing professionals come in. You can rely on our team to help you accurately set and defend arm’s-length intercompany pricing and prepare the various detailed documentation required by many countries.
From transfer pricing experts to international business and tax specialists (not to mention our Japanese business services group), our advisors provide fast, accurate assistance with contemporaneous documentation studies, planning analysis, transfer pricing design, advanced pricing agreements, audit defense, and more. Ultimately, the work we do allows our clients to benefit from improved profitability and cash flow in addition to standing up to scrutiny.
We offer an array of transfer pricing services to align with your overall tax planning, so you can focus on your business goals:
- Contemporaneous documentation studies: Our studies include an outline of company facts and history, market and industry benchmarking, definition of related-party transactions, and a detailed functional analysis of relevant entities. We can prepare documentation to comply with U.S. Section 482 Regulations, OECD Transfer Pricing Guidelines, and other countries’ rules. We’ll help you demonstrate past transactions were performed at arm’s length and comply with mandatory requirements from various countries. And we’ll help you mitigate penalty risk in the United States and prepare for potential tax audits.
- Transfer pricing planning and design: Instead of only documenting the past, we’ll proactively calibrate pricing for future transactions. This prospective analysis can easily serve as the basis for future documentation. We’ll help you establish your arm’s-length results for subsequent tax years, considering operational changes, while also minimizing the risk of tax penalties and optimizing tax planning. We can also help restructure your intercompany pricing policies and architecture and design global transfer pricing policies to simplify your transfer pricing administration.
- Advanced pricing agreements (APAs): Through negotiation with U.S. and foreign governments, we’ll structure advance pricing agreements for transfer pricing policies over a multiyear period. By attaining government buy-in, we’ll significantly reduce risk on both sides of the transaction. We’ll help you lessen the annual documentation burden and reduce the risk of transfer pricing audits, adjustments, double tax, and penalties. APAs also reduce risk for both past and future years with a potential “roll back” agreement.
- Transfer pricing audit defense: When it comes to transfer pricing audit and defense, our global team has experience supporting audit defense at all levels. If you have a full transfer pricing report prepared and ready for submission to the IRS, our team will step in and answer any questions posed by the IRS as they review your report. Alternatively, if you don’t have a transfer pricing report prepared for the IRS, we can provide that analysis on a short-term basis and then answer any follow-up questions.
