Transfer Pricing Services

Transfer pricing, the price determined for transactions between related entities, focuses on cross-border transactions, such as transferring goods, services, intangible assets, and intercompany loans.

Transfer pricing involves the setting of “arm’s length” pricing for almost every cross-border transaction including tangible goods, intangible property, services, royalties, and loans. When set against a backdrop of global tax authorities competing against each other for taxable revenue it is easy to see how transfer pricing touches every multinational business, both large and small, and how every transaction can trigger a potential tax liability and/or penalty.

Whether you are starting new entities, or your multinational company is thriving, mature transfer pricing should be on your to-do list.

With the heightened scrutiny from tax authorities, you shall be confident that you’re handling your intercompany pricing fairly and consistently.

ICS’s international tax experts provide transnational organizations with customized analyses. We can help you find opportunities to reduce your worldwide effective tax rate, satisfy documentation requirements, or resolve tax controversies.

ICS consistently delivers business tax savings and value through our strategic transfer pricing services. Our extensive transfer pricing planning experience allows us to coordinate the facts of your business with the laws and regulations of the countries where you do business in a way that both reduces risk and increases tax savings. This becomes your competitive advantage.

Our strategic transfer pricing services include:

  • Strategic design and implementation of U.S., international, and U.S. State & Local transfer pricing strategies
  • Intangible property migration and cost sharing arrangements
  • Global supply chain planning
  • Merger and acquisition due diligence and acquisition integration/merger strategies
  • Base Erosion Anti-Abuse Tax (BEAT)
  • Global Intangible Low-Tax Income (GLTI)
  • Foreign Derived Intangible Income (FDII)
  • Post-reform international intangible asset/intellectual property tax planning

Our transfer pricing compliance experience includes:

  • Global, and local country specific transfer pricing documentation
  • Internationally coordinated transfer pricing documentation
  • Reporting of intercompany transaction for both BEPS and FATCA purposes
  • Coordination of transfer pricing strategies with VAT, and Customs pricing policies
  • Transfer pricing reporting for IFRS, and local country GAAP

Our transfer pricing dispute resolution experience includes:

  • Support from audit initiation through high court legal proceedings
  • Local country legal and tax authority representation
  • Competent Authority (“CA”) representation
  • Advance Pricing Agreements (“APA”)