International Transfer Pricing

Taking a Proactive Approach to International Transfer Pricing

Crowe Horwath LLP helps multinational organizations reduce uncertainty in measuring and reporting the results of transactions across diverse tax jurisdictions. Our experience includes helping companies address complex international tax issues related to transfer pricing.

Our Transfer Pricing professionals are supported by highly educated economists to provide insights into the intricacies of transfer pricing analyses as well as guidance on tax transactions. We can help: assemble the required documentation; resolve disputes with domestic and foreign tax authorities; develop an effective transfer pricing policy; prepare advance pricing agreements; determine the tax implications of intellectual property; and assess risk and opportunity in cross-border transactions.

Crowe's experienced Transfer Pricing professionals are here to:

  • Reduce transfer pricing risks with comprehensive tax due diligence
  • Substantiate good faith efforts to establish and maintain “arm’s-length” pricing
  • Provide a “best-efforts” platform for effective and efficient resolution of transfer pricing inquiries
  • Develop proactive strategies for interactions with each country of operation
  • Proactively help companies adopt recommendations of Organisation for Economic Co-operation and Development (OECD)'s Base Erosion and Profit Sharing (BEPS) Initiative

To meet the increasing sophistication of tax authorities with respect to transfer pricing regulations and penalties, our transfer pricing specialists provide economic consulting services in a number of specific areas, including:


  • Evaluate current transfer pricing policies and documentation
  • Prepare regulatory compliant transfer pricing documentation
  • Provide due diligence for M&A transactions and tax provisions

Strategic Planning

  • Plan efficient and effective transfer pricing policies
  • Evaluate the impact of new and/or proposed transfer pricing regulations
  • Set global pricing structures for new intercompany transactions
  • Prepare and Evaluate Cost-Sharing Agreements
  • Prepare Advanced Pricing Agreements


  • Evaluate and provide suggested language for intercompany agreements
  • Implement transfer pricing policies and compute adjustments
  • Provide guidance for accounting systems to effectively manage transfer pricing policies

Audit Defense, Litigation Support, and Dispute Resolution

  • Prepare economic analyses for litigation or audit defense
  • Participate in negotiations with local country tax authorities
  • Implement OECD documentation requirements
Contact Us
Barry T. Freeman