Mitigate Risk, Optimize Efficiency with Transfer Pricing Solutions
In today’s increasingly global economy, international expansion is a critical growth strategy for businesses. At the same time, tax authorities around the world are allocating ever-growing resources to enforce transfer pricing laws. Transfer pricing can be considered complex and fraught with risk, but can also be a valuable tool for companies to utilize in managing their operations and tax exposure.
Bennett Thrasher’s experienced transfer pricing experts will work directly with you to establish effective transfer pricing strategies in the countries where you do business in a way that reduces risk while increasing tax savings. Our experienced professionals can help you develop transfer pricing strategies that are both compliant and advantageous for your business.
Bennett Thrasher’s Transfer Pricing professionals can help you navigate global risks and opportunities by:
- Planning: Working with you to review or design your company’s policies related to the intercompany transfer of goods, services and intangibles across borders by conducting value chain analyses, characterizing entities functional profiles and determining appropriate pricing models
- Documentation: Preparing transfer pricing documentation to evaluate the arm’s length character of intercompany transactions. We can prepare U.S documentation as well as documentation meeting BEPS requirements, including the Country-by-Country Report (CbCR), Master File and Local File
- Benchmarking and Valuation: Identifying appropriate arm’s length pricing for the transfers of tangible property, services and intangible property (e.g., trade names, software rights, manufacturing know-how, etc.)
- Intercompany Financing: Performing debt capacity, creditworthiness and interest rate benchmarking studies to appropriately determine intercompany financing arrangements
- Implementation: Turning transfer pricing recommendations into actionable policies and procedures for ongoing operational purposes, financial reporting and tax compliance
- Advance Pricing Agreements (APAs): Assisting with the negotiation of APAs with the IRS and foreign tax authorities to avoid potential future disputes
- Controversy and Audit Support: Defending transfer pricing positioning in U.S. and foreign tax audits, and supporting clients through Mutual Agreement Procedure and Competent Authority processes
Multinational businesses – including small and medium-sized companies – need a carefully thought out transfer pricing policy that mitigates the risks of forced income adjustments and penalties. These policies also need to align 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 ways to increase tax efficiency, and the policies that make sense today might not always be in your organization’s long-term best interest.
Our team will gain a thorough understanding of the nature of your company’s international activities, the specific transactions at play and the long-term objectives of your organization. Our deep level of involvement and insight allows us to work together with you to create an approach that satisfies the relevant rules and regulations while being efficient and practical to implement.