Voluntary Disclosure vs. Managed Audit: Choosing the Best Path to Reduce Tax Risk
In today’s 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 it can also be a valuable tool for companies to better manage their operations and limit their tax exposure.
Bennett Thrasher’s experienced transfer pricing experts can help you build transfer pricing strategies that reduce risk and increase tax savings while maintaining compliance with domestic and international authorities.
If you are looking for a partner to assist with your multinational corporation’s transfer pricing strategy, we can help. Contact Ben Miller to schedule a consultation.
We can defend transfer pricing positioning in domestic and foreign tax audits. We can also support you through Mutual Agreement Procedure and Competent Authority processes.
We can review or design your company’s policies related to the intercompany transfer of goods, services, and intangibles across borders. We do this by conducting value chain analyses, characterizing entities’ functional profiles, and determining appropriate pricing models.
We can prepare transfer pricing documentation to evaluate the arm’s length character of intercompany transactions. We can prepare US documentation and documentation meeting BEPS requirements, including the Country-by-Country Report (CbCR), Master File and Local File.
We can identify appropriate arm’s length pricing for the transfers of tangible property, services, and intangible property (e.g., trade names, software rights, manufacturing know-how)
We can perform debt capacity, creditworthiness, and interest rate benchmarking studies to determine appropriate intercompany financing arrangements.
We can turn transfer pricing recommendations into actionable policies and procedures for ongoing operational purposes, financial reporting, and tax compliance.
We can help you negotiate APAs with the IRS and foreign tax authorities to help you avoid future disputes.
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 your company’s international activities, the transactions at play, and the long-term objectives of your organization. We will work with you to create an approach that is not only efficient and practical, but that also satisfies the relevant rules and regulations.
We can defend transfer pricing positioning in domestic and foreign tax audits. We can also support you through Mutual Agreement Procedure and Competent Authority processes.
We can review or design your company’s policies related to the intercompany transfer of goods, services, and intangibles across borders. We do this by conducting value chain analyses, characterizing entities’ functional profiles, and determining appropriate pricing models.
We can prepare transfer pricing documentation to evaluate the arm’s length character of intercompany transactions. We can prepare US documentation and documentation meeting BEPS requirements, including the Country-by-Country Report (CbCR), Master File and Local File.
We can identify appropriate arm’s length pricing for the transfers of tangible property, services, and intangible property (e.g., trade names, software rights, manufacturing know-how)
We can perform debt capacity, creditworthiness, and interest rate benchmarking studies to determine appropriate intercompany financing arrangements.
We can turn transfer pricing recommendations into actionable policies and procedures for ongoing operational purposes, financial reporting, and tax compliance.
We can help you negotiate APAs with the IRS and foreign tax authorities to help you avoid future disputes.
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 your company’s international activities, the transactions at play, and the long-term objectives of your organization. We will work with you to create an approach that is not only efficient and practical, but that also satisfies the relevant rules and regulations.
“The transfer pricing audit ended after the German tax authorities reviewed our Local File. It might have been the best money I have ever spent.” – Feedback from Finance Director of Irish Multinational in Healthcare Industry following a transfer pricing audit in Germany
“Ben and his staff have been fantastic. They have been very professional and extremely patient as we navigate through our transaction and the planning process.”
“We are incredibly grateful for the partnership, support and collaboration of you and your team…Your professionalism and collaboration truly made the difference for the Company, our teams and our leaders.”
“As always, we very much appreciate your hard work and the hard work of the entire BT team.”
“In the past, I have used two of the top four national accounting firms for advice. I have found Jeff Call’s firm Bennett Thrasher, the most responsive, always available and very, very helpful. Once I’m not around, I’m certain my state trustee will continue to rely on Jeff’s firm.”
“Bennett Thrasher provided exceptional second mile audit services for Trilith Studios. Their team was thorough, knowledgeable, demonstrated a high level of attention to detail and provided clear communication throughout the entire process. We highly appreciated their collaboration and the professional service they provided throughout the entire audit process.”
“Just when you have self-assessed your company to possibly be the worst client ever, the Staff at Bennett Thrasher make you feel like you are their most important and beloved client. That ability is an attribute you don’t see in many accounting firms.”
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