Transfer Pricing

Our Expertise
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.

Operational transfer pricing

With new Base Erosion and Profit Shifting (BEPS) reporting requirements, it's more important than ever that multinational companies efficiently collect, validate, and standardize their data. Our team of transfer pricing experts can support you with the implementation of enterprise systems and processes that help you keep up with local tax rates and transfer pricing rules, achieve compliance, mitigate risk, and forecast results.

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.


Stay informed on tax rates and policy changes


Preparing for change: What you need to know about international regulations and transfer pricing

Client Experience
Seamless global service on your side

To align transfer pricing policies with your evolving business needs, you need to see the full global picture. We provide that perspective, drawing on:

  • Our international business and tax experts
  • Professionals from our firm-owned offices in China, India, Japan, and Mexico
  • Our contacts at international tax authorities
  • Our alliance with Praxity, AISBL, the seventh largest and fastest growing accounting association in the world

In the words of Kari Thiessen, our firm’s transfer pricing director, “If your business operates internationally or is planning to expand across borders, transfer pricing should be top of mind. It’s our goal to help clients anticipate and solve international tax problems before they arise and provide insights on the opportunities and impact of international growth.”