Transfer Pricing

Mitigating Risk with Transfer Pricing Solutions

In today’s increasingly global economy, international expansion is a critical growth strategy for businesses of all sizes and in almost every industry. However, with tax authorities around the world allocating ever-growing resources to enforcement of their transfer pricing laws, the task of setting transfer prices for intercompany transactions is becoming more complex and fraught with risk.

Multinational businesses-including small and medium businesses-need a carefully thought out transfer pricing policy that mitigates the risks of forced adjustments and penalties, and also aligns with strategic business objectives from improving cash flow and supply chain efficiency to managing global effective tax rates and uncertain tax positions. There are many routes available to increase tax efficiency, and the decisions that make sense today aren’t always in your organization’s long-term best interests. Determining the most effective transfer pricing strategy depends on a thorough understanding of the nature of the corporation’s international activities, the specific transactions at play and the long-term business objectives of the firm.

Bennett Thrasher can help you create value by developing transfer pricing strategies that are both compliant and advantageous for your business. Our transfer pricing specialists work hand-in-hand with our clients to truly understand the global corporate structure and overall vision of the company, and this deep level of involvement and insight allows us to work together with you to create a transfer pricing approach that satisfies the relevant transfer pricing rules and regulations while being efficient and practical to implement.

Bennett Thrasher’s transfer pricing team members have extensive experience designing, implementing and maintaining transfer pricing policies on behalf of public and private companies in a wide range of industries. We can help you navigate global transfer pricing risks and opportunities by:

  • Teaming with you to design or review your company’s transfer pricing policy(ies) related to the movement of goods, services and/or intangibles across borders
  • Preparing transfer pricing documentation to evaluate the arm’s length character of intercompany transactions based on the U.S. transfer pricing regulations and laws in foreign jurisdictions
  • Valuing intangible property, including trade names, software rights, manufacturing know-how, and more
  • Assisting with the negotiation of advance pricing agreements (APAs) with the IRS and foreign tax authorities to avoid potential future disputes
  • Defending transfer pricing positions in U.S. and foreign tax audits and supporting clients through Mutual Agreement Procedure and Competent Authority processes

For a confidential consultation regarding your multinational corporation’s transfer pricing strategy, contact Ben Miller or call 770.396.2200.