Any time related parties on different sides of international borders conduct business, the taxing authorities from both countries want to insure both entities are recognizing the appropriate income and paying their "fair share" of taxes. Generally referred to as "transfer pricing," the transactions may be related to tangible goods, intangible goods, services provided by either entity to the other and/or financing arrangements. Who is at risk? U.S. subsidiaries of foreign parent companies and U.S. parents with foreign subsidiaries are at risk of audit and having their intercompany transactions scrutinized by both the Internal Revenue Service and the corresponding foreign taxing authority.
Transfer pricing rules are complex but can be used to generate significant benefits via a reduction in the overall corporate tax rate while still complying with each taxing authority's regulations. Clifton Gunderson transfer pricing specialists have provided transfer pricing services to companies large and small in a wide variety of industries. Our key advantage is the hands-on involvement of our experienced partners and senior managers in every facet of each transfer pricing engagement. This insures your management team receives the full benefit of their knowledge and experience with taxing authorities around the world.
Examples of the transfer pricing services provided include:
- Transfer pricing documentation
- Functional and risk analyses
- Economic intercompany pricing and interest rate analyses
- State-to-state transaction analysis
- Development of global transfer pricing policies
- Advanced pricing agreements
- Cost sharing agreements
- Dispute resolution
Clifton Gunderson can assist you in achieving your global strategies by working proactively with management to reduce the potential for costly audits and related penalties based on our knowledge and experience with taxing authorities worldwide.
Transfer Pricing Insight
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Whitepaper - Overview of US Transfer Pricing Regulations
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