Transfer Pricing
Service description
Transfer pricing is about determining fair market value for internal corporate transactions, meaning the exchange of good, services, or assets amongst related entities. Transfer pricing strategies aim to minimize tax liability, identify tax advantageous opportunities, and survive tax authority scrutiny. Examples of transfer pricing include:1. The sale of goods between a subsidiary manufacturer and a subsidiary distribution.2. the provision of technical support between related entities.3. The licensing of intellectual property, like trademarks or patents, to related entities.
Benefit
Set and document defensible pricing for transactions between related entities across borders, meeting IRS and foreign-jurisdiction requirements.
ROI
Proper documentation avoids steep transfer-pricing penalties and double taxation and holds up under audit.
Further research
(i) Internal Revenue Code at Section (IRC) 482 (ii) Organization for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises (MNEs) on Responsible Business Conduct (iii) Country Specific Tax laws & Regulations
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