WithumSmith+Brown, PC (Withum) offers a full line of value-added global transfer pricing specialty services. Transfer pricing is a universal issue, applying to cross-border intercompany transfers across all industries, related to all business functions and locations around the world.
Global Transfer Pricing Documentation
Withum provides economic analyses and reports to comply with US Section 482 Regulations, OECD guidelines and foreign jurisdiction regulations. Preparing this annually is the key to minimizing steep penalties of 20% to 40%.
Global Tax Minimization Planning
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.
Base Erosion Profit Sharing (BEPS) Compliance
OECD’s BEPS initiative compliance for MNEs with $850 million (euro$750 million) or more in world-wide annual revenue. Withum’s Transfer Pricing and International Tax Services Teams prepare Country-by-Country Reporting (CbCR) forms and other filings.
Transfer Pricing Controversy
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
Advance Pricing Agreements (APAs) are useful tools for negotiating future transfer pricing positions at the competent authority level.
- Unilateral, Bilateral or Multilateral APA Options
- Stops Contentious Audit Situations in Open Past Years
- Option for Controversy Cases on Their Way to Tax Court
- Planning Tool for Risk-Averse Clients Seeking Certainty
Other Transfer Pricing Advice and Assistance
- Setting Corporate Policy
- Review of Intercompany Legal Agreements
- Implementation of Recommended Pricing and Policies
- Cost Identification and Allocation Methodology
Full Line of Value-Added Specialty Services
- Documentation: U.S., OECD and Country Regulations
- Planning: Global Tax Minimization
- BEPS CbCR: Preparation and Review of Forms
- Controversy: Assistance with Audit Defense
- APA Negotiations