Transfer Pricing

In today’s global business environment, the volume and complexity of the cross-border transactions entered into by multinational companies regularly result in taxpayer examinations producing adjustments to taxable income related to the taxpayer’s transfer pricing policies and procedures as taxing authorities around the world utilize transfer pricing to maximize tax revenue in their local jurisdictions.

The U.S. Internal Revenue Service ("IRS"), like many taxing authorities around the world, continues to place transfer pricing high on its list of priority issues. This has resulted in the implementation of significant transfer pricing documentation requirements, firmer enforcement of penalties for non-compliance, and a general increase in examination activity related to transfer pricing. This fact, combined with the continuously evolving regulatory environment of taxing authorities around the world, produces a scenario where a heightened effort towards transfer pricing planning and compliance both in the U.S. and abroad is imperative from a risk mitigation perspective.

Most cross-border operating companies are subject to a range of risk from minor to significant with regards to transfer pricing. Our U.S. transfer pricing team has been assisting our clients with navigating the complexities of documentation for more than three decades, as well as providing IRS examination support. Our clients benefit from our ability to work with Rödl & Partner’s global transfer pricing group to ensure cross-border consistency.

Our transfer pricing services encompass planning and documentation solutions that help clients with:

Complying with local and international documentation requirements, including a discussion on the differences between U.S. and foreign transfer pricing documentation
Managing intercompany transaction structuring and global profit allocations
Reducing exposure to transfer pricing adjustments being proposed/sustained by taxing authorities
Protecting against costly penalties that can be assessed during tax return examinations

OUR U.S. TRANSFER PRICING TEAM SPECIFICALLY OFFERS THREE LEVELS OF SERVICES:

Benchmarking
Economic Analyses
Comprehensive Documentation

TP Global Update - Transfer Pricing News

The “Transfer Pricing” practice of Rödl & Partner supports its internationally active clients with the individual design, documentation and defence of cross-border intra-group business relationships. The TP Global Update provides expert articles on a regular basis about recent developments and shares practical experiences related to transfer pricing.