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Global Transfer Pricing

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 worldwide annual revenue. Withum’s Transfer Pricing and International Tax Services Teams prepare Country-by-Country Reporting (CbCR) forms and other filings.

Base 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

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