Transfer Pricing Services for a Borderless Economy

If your business is multinational – or will be – doing business with related parties abroad will add complexity to your ability to comply with the expanding web of transfer pricing rules and regulations.

As with many tax matters, there are nuances that can trip up even the most diligent financial leaders without the support of a strong team of tax accountants and advisors who have expertise in the global transfer pricing environment. Risks include double taxation resulting from transfer pricing examinations, lack of compliance on local documentation requirements in multiple international locations and missed opportunities for planning that can provide tax-optimized transfer pricing policies.

Lead by Brad Pittman and Jackson Moore, the Specialty Tax Services team at Smith + Howard works with global entities to help them get and stay aligned with transfer pricing rules. We tailor our approach to the address the complexity and compliance with rules and regulations based on your specific needs.

1. Benchmarking: Analyses that allow end users to gain an overall or transaction-level view to profitability for their business. Whether foundational or supplemental to existing tools, they can move the business towards compliance, but generally do not meet IRS Section §6662 documentation requirements and are not intended to serve as comprehensive transfer pricing documentation to support a taxpayer’s existing intercompany pricing policies.

2. Economic Analyses: Slightly expanded in scope relative to benchmarking, economic analyses answer the important question of whether a taxpayer’s intercompany transactions in the subject year met the arm’s length standard prescribed under the U.S. transfer pricing rules. An economic analysis represents the profit benchmarking component that is critical for most U.S. transfer pricing documentation and can be modified later to meet documentation requirements present in a comprehensive documentation engagement (see number 3 below).

3. Comprehensive Documentation: Comprehensive documentation engagements are appropriate when the highest level of assurance and risk mitigation is desired. In these engagements, we deliver documentation that is aligned with the IRC §6662 requirements. This put clients in the best possible position for a possible transfer pricing examination, reducing and in many cases eliminating risk of the imposition of penalties should an adjustment to taxable income be proposed and sustained during the course of an IRS examination.

Enterprises operating at the global level rely on and trust the expertise of the Specialty Tax Services team at Smith + Howard. Connect with us on the Contact an Advisor button below and Brad Pittman or Jackson Moore will respond quickly.