Transactions with foreign related parties are required to be completed at arms-length and priced at a level comparable to transactions with unrelated third parties. Transfer pricing transactions, policies and documentation have received heightened scrutiny in recent years and substantial penalties can be assessed by the IRS. Our firm is qualified to assist in the preparation of, or consultation on, transfer pricing studies in order to mitigate this potential business risk.
- Preparation of North American transfer pricing study for multinational company, with specific focus on management fees, treasury services and inventory pricing.
- Assistance in successful response to IRS notice involving client's inventory transfer pricing, including detailed analysis of inventory pricing compared to our client's peer group.
- Preparation of transfer pricing documentation for purposes of annual assessment of uncertain tax positions, including review and resolution with client's external audit firm.
- Assistance with transfer pricing IRS audit and resulting competent authority remediation process.
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