We assist multinational groups in preparing fully compliant transfer pricing documentation, tailored to the requirements of each jurisdiction in which they operate.
Services include:
Benefits:
Strategic alignment of intercompany pricing with functional reality
Beyond compliance, we help clients proactively structure and evaluate their intercompany arrangements.
Services include:
Use cases:
We support clients in preparing, evaluating, and negotiating unilateral, bilateral, or multilateral APAs.
Services include:
Why it matters:
APAs provide certainty and avoid costly disputes. Our role is to ensure your APA is technically sound and defensible.
We perform robust, defensible valuations of intangible assets and business operations for tax, legal, and strategic purposes.
We value:
Methods applied:
Our benchmarking studies support arm’s length pricing of intercompany transactions by identifying reliable comparables.
We conduct:
Tools & databases:
Amadeus, Orbis, RoyaltyStat, ktMINE, Bloomberg, LoanConnector, S&P Capital IQ
We help companies manage and resolve transfer pricing audits and disputes by preparing technical responses, rebuttal reports, and strategic defense positions.
Services include:
We bridge the gap between transfer pricing and international tax strategy, supporting clients in optimizing global tax structures.
Key areas:
We frequently partner with in-house tax teams, CFOs, and legal counsel to build knowledge and capacity.
What we offer:
We help you establish clear and defensible transfer pricing policies aligned with your business strategy and industry best practices.
Our experts conduct thorough analyses to identify arm’s-length prices for your specific transactions (tangible, services, intangible and financial).
We can assist you in preparing comprehensive documentation that meets IRS requirements and supports your transfer pricing positions.
We help you accurately value intangible assets like trademarks and patents for transfer pricing purposes.
We provide guidance on complying with increasingly important state-specific transfer pricing regulations.
Our experienced team can support you during IRS audits, advocating for your position and minimizing potential tax adjustments.