Andersen Tax

Transfer Pricing

The experienced professionals of Andersen Tax, and the member firms and collaborating firms of Andersen Global, are ready to meet your domestic and global transfer pricing needs. We have extensive experience advising emerging businesses and multinational organizations through all aspects of their tax management lifecycle – planning, implementation, compliance, and controversy. We help you ensure that your tax positions are practically and properly aligned with your business operations.

Companies in the early stages of international expansion often consider migrating intellectual property (IP) or off-shoring various aspects of their supply chains. At the same time, more established companies tend to have complex supply chains, reflecting the cumulative impact of M&A activity and/or operational consolidation. Because companies at different stages in their development have different tax needs and obligations, our team can proactively advise on how to best structure the corresponding related-party transactions and design, implement, and document a transfer pricing policy that makes sense for your business.

We can help your company with all aspects of transfer pricing, including:

  • Planning and Implementation – Design new tax structure as you grow globally and move business functions to new locations.
  • Documentation – Prepare U.S. and OECD-compliant contemporaneous documentation reports for the jurisdictions in which your business operates.
  • IRS and Foreign Controversy/Audit Support and Defense – Defend your transfer pricing policy with IRS or foreign tax authorities. Likewise, we can help limit uncertainty with your transfer pricing policy by pre-negotiating your position with tax authorities through private rulings or, in the case of the U.S., the Advanced Pricing and Mutual Agreement Program.
  • IP/Cost Sharing Planning – Properly value IP for tax purposes in order to safeguard against tax authorities claiming that IP rights were transferred without reasonable compensation.
  • Country by Country Reporting (CbCR) – As BEPS Action 13 continues to be implemented by an increasing number of countries, it is imperative for businesses (especially large enterprises) to ensure that the narrative of the CbCR forms accurately reflects where their functions, assets and risks are located, and does not suggest one that allows tax authorities to impute an alternative interpretation more to their liking.

Our approach to transfer pricing is built to provide solutions that are clear, comprehensive, concrete and convincing. Let our experienced Andersen Tax professionals help you solidify your transfer pricing position.