Transfer Pricing

The Advise LLP Transfer Pricing team supplies financial advisory assistance relating to tax implications stemming from sales transactions between controlled entities

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Employing Transfer Pricing

The Advise LLP Transfer Pricing team supplies financial advisory assistance relating to tax implications stemming from sales transactions between controlled entities. As the goal of “transfer pricing” is to ascertain whether company interdivisional transfers of cost, expense, tangible/intangible goods, rendered services, and loan/monetary transactions are compatible with the IRS arm’s-length standard.

To address the growing intricacy of tax administrations as they relate to transfer pricing regulations, our transfer pricing team offer financial advisory services in a range of distinct areas, as follows:

IRS Sec. 482 Compliance

  • Generation of documentation to adhere to IRS regulations.
  • Offer thorough examination of ongoing transfer pricing procedures and policies to identify risk.
  • Team with consultants to devise necessary, location-distinct documentation
  • Analyze Transfer Pricing penalty liability on transactions for M&A investigative care and tax regulation objectives.
  • Evaluate reviews generated by internal tax offices or external tax advisors to substantiate an unbiased and detached viewpoint.

Critical Preparation

  • Design streamlined and tenable transfer pricing protocols to minimize IRS tax exposure amidst the purview of regulatory mandates.
  • Consider recent guidance and create procedures that adhere to these directives.
  • Generate and/or review cost-transfer relationships to determine compatibility with directives.

Utilization

  • Furnish taxpayers with tenable protocols that do not cause unneeded organizational hardships.
  • Execute transfer pricing protocols.
  • Calculate transfer pricing benefit for each entity in a transaction.
  • Furnish direction in regards to tax/accounting structure products to calculate transfer prices and proficiently administer transfer pricing protocols.

Audit Response, Legal Advocacy, and Dispute Settlement

  • Furnish, where permitted, adept attestation and transfer pricing/financial reviews in support of audit response or legal action.
  • Engage in negotiations with IRS tax officials.

Through Advise LLP’s, we have the wide-ranging means to aid customers in meeting their transfer pricing demands. Advise LLP’s assistance capabilities offer support for interdivisional transfers in domestic territories. Our Transfer Pricing team have extensive backgrounds in creating unified resolutions to pricing concerns.

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