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Global Transfer Pricing Strategies

Transfer Pricing is the internal pricing charged between affiliated companies operating in different tax jurisdictions around the world. Global transfer pricing strategies include intercompany activity related to these four types of transfers between affiliated companies:


Tangible goods

Product purchase/sale


Services

Provision of management, G&A, R&D, etc. services


Intangible assets

Licensing of intellectual property, technology-related or marketing/brand-related


Intercompany financing

Loans, lines of credit, cash pooling

Contact our Withum Tax Professionals to discuss planning ideas applicable to your situation.

International taxation is undergoing the biggest shake-up for a generation. The already complex world of transfer pricing is at the front and center of these disruptive changes. There has never been a better time for companies to reevaluate their current transfer pricing strategies. Withum’s global transfer pricing professionals can assist in developing tax-efficient, as well as operationally-efficient, strategies that conceptualize, analyze, and implement appropriate transfer pricing principles.

Withum’s global transfer pricing strategies team works with clients to explore value-added planning opportunities, as well as annual compliance documentation. In advising on the economic substance needed to support the functions and risks in all related entities around the world, companies can facilitate their global structuring. A transfer pricing study is the taxpayer’s first line of defense in the case of an IRS audit. Through 20 plus years of in-house expertise, and its global alliances with HLB, Withum can prepare the appropriate global and local documentation to support transfer pricing in US and foreign jurisdictions, defend transfer pricing in IRS and local audits, and negotiate advance pricing agreements. We help clients to navigate the impact of the ever-changing global landscape around transfer pricing in both the US and world-wide, including OECD initiatives around BEPS, Country-by-Country reporting (Master File and Local File), and the unified approach to taxing the digital economy.
Authors: Marina Gentile | mgentile@withum.com and Andrew Desimone | adesimone@withum.com

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