Our full line of global transfer pricing strategies provide your international business with value-added accounting, advisory, and consulting.
Our Suite of Transfer Pricing Services
Dependable transfer pricing analysis is a universal issue, applying to cross-border intercompany transfers across all industries, related to all business functions and locations around the world. Our global transfer pricing solutions and services include:
Transfer pricing is the biggest tax uncertainty for multinationals. Withum provides transfer pricing advisory services to determine and establish arm’s length intercompany pricing for startup companies just expanding globally, as well as to mature established global businesses. Taking a fresh look to assess the health of your transfer pricing ensures an optimal global structure that minimizes transfer pricing risk around the world.
Withum provides economic analyses and documentation reports to comply with US Section 482 Regulations, OECD Guidelines, and foreign jurisdiction regulations. Preparing this annually at the time of the tax return filing is the key to minimizing steep penalties of 20% to 40%, and to maximizing your best negotiating position.
Withum performs economic benchmarking analyses for those firms that require a lighter touch approach to transfer pricing. This arm’s length transfer pricing is delivered in a PowerPoint or memo and ensures you have the right transfer pricing to use in your accounting.
Proactive reviews of companies’ global operations from a transfer pricing and international tax perspective. Transfer pricing strategy is a key tool to ensure multinational corporations are operating in the most globally tax-efficient manner. The combined expertise of Withum’s transfer pricing and international tax professionals bring a two-phased discovery/design and implementation approach to optimize your global structure.
Withum transfer pricing professionals are skilled in OECD’s Base Erosion and Profit Shifting (BEPS) initiative compliance. This includes preparation of Master Files, Local Files, and Country-by-Country Reporting (CbCR) for those who meet individual country thresholds. Withum’s transfer pricing and international tax professionals prepare CbCR forms for MNEs with USD$850 million (EUR$750 million) or more in worldwide annual revenue.
Withum professionals have successfully represented clients in transfer pricing matters.
- Representation with IRS and Foreign Tax Authorities
- Oral and Written Responses to Information Data Requests (IDRs)
- Counter-Analyses to Tax Authority Notice of Proposed Adjustments (NOPAs)
- Economic Analyses to Support Legal Proceedings in Tax Court
- Advance Pricing Agreements (APAs) to negotiate and lock in future transfer pricing
- Competent Authority negotiations to avoid double taxation
- Planning: Establishing transfer pricing risk mitigation and global tax minimization
- Documentation: Annual compliance with U.S., OECD and Local Country Regulations
- Benchmarking Analyses: Determining arm’s length pricing for accounting
- Global Tax and Transfer Pricing Strategies: Establishing optimal global structure
- OECD BEPS Compliance: Preparation of Master Files, Local Files, CbCR
- Controversy and APA Negotiations: Assistance with Audit Defense and prospective TP
- Domestic Transfer Pricing
- Cost Allocation Studies
- Transaction Advisory Transfer Pricing Diligence
- Review of Intercompany Legal Agreements
- Operational Transfer Pricing: Implementation of Recommended Pricing and Policies
- Protection of Intellectual Property
- Cash Flow Management
Why Choose Withum for Your Global Transfer Pricing Services
With 25 years of expertise, our Transfer Pricing team provides top-tier consulting services for international organizations headquartered all over the world. Our strategic approach to global transfer pricing analysis and advisory combines economics, tax, and accounting to determine a custom tailored strategy to fit the unique needs of your business.
For additional information or questions about your global transfer pricing strategies, contact a member of Withum’s team.
Share It’s been another intense year for transfer pricing, and the expectation is that it will continue. Once an obscure area of International Tax law, transfer pricing is going mainstream […]
Share The Organisation for Economic Co-Operation and Development (“OECD”) announced last Friday that after years of negotiations and efforts, 136 world economies have agreed to a Global Minimum Tax (“GMT”) […]
Comparing taxes among countries is a hobby for some, a talking point for others and an important metric for those that devise strategies or who track foreign trade and investments. However, it is an uneven process. Currencies, tax rates and how they are applied, fluctuating economic conditions, population sizes, governmental restrictions and regulations, the tax base and what is taxed and extraterritorial activities vary making comparisons inaccurate.