Transfer Pricing

EisnerAmper takes a practical approach to transfer pricing planning and compliance that helps companies manage risk while taking advantage of planning opportunities.

As organizations expand globally, they face increasing complexity in managing transfer pricing. With heightened scrutiny from tax authorities worldwide, a robust transfer pricing strategy is essential.

What is Transfer Pricing?

Transfer Pricing refers to how transactions between related parties are priced. Transactions can involve tangible or intangible property, services, or various financial transactions (such as loans, guarantees, and cash pools).

Governments worldwide have enacted transfer pricing rules to protect their jurisdictions’ tax bases. These rules empower tax authorities to challenge intercompany pricing aggressively and assess penalties if companies do not have appropriate policies or documentation in place.

Our Transfer Pricing Services

Transfer Pricing services

EisnerAmper’s experienced team of international tax experts, accountants, and economists can help you:

Planning
State-to-State (Domestic) Transfer Pricing
Risk Mitigation and Compliance
Tax Authority Controversy
Focus on Intellectual Property
Focus on Start-ups and Newly Inbound/Outbound Expansion
Other Services

Planning

Whether companies are in the start-up phase or expanding into new markets, transfer pricing issues should be addressed in the planning process to avoid risk.

Right-sized assistance for start-ups and businesses newly expanding into foreign jurisdictions
Support with restructurings to design transfer pricing policies that align with new and changing intercompany dealings and relationships

State-to-State (Domestic) Transfer Pricing

Companies are facing increasing scrutiny on transactions between entities domiciled in different states.

Review for potential state and local tax exposures
Assistance with meeting state transfer pricing compliance requirements

Risk Mitigation and Compliance

Most countries require annual transfer pricing compliance.

US documentation studies
OECD and foreign Local File and Master File preparation
Support in securing Advance Pricing Agreements and Mutual Agreement Procedures
For SEC registrants, ASC740 (FIN48) review

Tax Authority Controversy

Tax authorities are challenging transfer pricing positions more aggressively than ever before.

Tax audit defense
Litigation support, including expert witness representation
Assistance with competent authority negotiations

Focus on Intellectual Property

Due to globalization trends, intellectual property (IP) is crossing international borders between related parties at a record pace. Even though your cross-border transactions may appear seamless, the IRS and other tax authorities may be watching.

IP valuation
IP planning and migration
Determination of royalty rates for licensing transactions
Consolidating IP for risk mitigation or sale preparation purposes

Focus on Start-ups and Newly Inbound/Outbound Expansion

Tax authorities have been increasingly scrutinizing smaller companies and new entities due to the taxpayer's perceived lack of preparedness.

IP planning to help companies keep IP where they want it
Pricing tangible product transfers to manage customs, duty, and potential tariffs
Determining pricing of new intercompany services, including management services, R&D, or headquarters functions
Managing withholding taxes that can apply to intercompany interest payments, royalties, or other forms of remuneration
Examining tax benefits/incentives such as R&D credits or patent box regimes
Navigating the complexity of a foreign country’s transfer pricing regulations

Other Services

Acquisition integration assistance
Cost sharing arrangements
Due diligence for M&A
General consulting
Income tax provision support
Tax efficient global supply chain strategy

team meeting

Why Choose EisnerAmper

Whether your company needs guidance with transfer pricing policies or help meeting compliance requirements, EisnerAmper’s team is here to help.

Deep Expertise: Our team stays up-to-date on the latest transfer pricing developments.
Practical Approach: We provide tailored solutions to meet your specific needs.
Global Reach: Our network of professionals can assist you with cross-border transactions.