Our services in this area include the following:
We are routinely called upon to assist in designing and pricing supply chain, intangible property and other intercompany transaction structures. Our efforts in this area include the development of effective and reliable methods for pricing guarantee fees, pricing intercompany debt, developing profit splitting structures and numerous other transfer pricing analyses. Importantly, our planning efforts are always conducted with the potential for downstream controversy risk in mind. Our significant controversy experience allows us to develop defensible transfer pricing structures that avoid tax authority scrutiny.
In some cases, our clients wish to use us as a second set of eyes when implementing large global planning structures. We are generally able to assess the tax impact, and evaluate the risks, of planning positions related to complex global supply chain structures much more quickly, and we believe more thoughtfully, than our Big 4 competitors. We also co-develop cost effective transfer pricing master file documentation, as well as single country documentation files.
Our documentation efforts generally center on documenting structures that we have assisted in designing. However, we also provide initial documentation for client’s existing transactions, as well as documentation updates for those transactions. Our approach to documentation is highly cost effective.
Proven Thought Leadership
We are thought leaders in the areas of transfer pricing, the integration of international tax planning and transfer pricing into structures built to be sustainable and defendable, the analysis and pricing of substance in hybrid tax structures and have gained notoriety worldwide through our presentations and lectures given at top venues around the world.