Transfer Pricing

A Proactive Approach to Transfer Pricing

Intercompany transactions that cross multiple tax jurisdictions can create challenges for any organization. To fully understand the increasingly complex implications, many company seek a specialized tax consultant to help them address the multifaceted transfer pricing challenges that accompany intercompany trade.

At Crowe Horwath LLP, 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:

  • 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 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

Our transfer pricing services include:

Compliance

  • 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

Implementation

  • 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
Principal