Our transfer pricing successes:
- Successfully defended multinational taxpayers against IRS economist and international examiner transfer pricing attacks, avoiding all adjustments and penalties.
- Developed in-house comparables transfer pricing strategies for our clients, avoiding the need for the company to rely on public databases and database fees.
- Substantiated reinvoicing activities in a tax haven relationship between two high-tax jurisdictions. Successfully substantiated DISC FISC subsidiary structure to substantiate FISC transfer pricing activities.
- Successfully defended foreign-based multinational taxpayers against IRS attempts to restructure SIC/NAICS categorization, avoiding all adjustments and penalties.
- Successfully defended major multinational corporations against IRS documentation claims, avoiding all adjustments and penalties.
What we are doing now in transfer pricing:
- Structuring Singapore/US coordinating service arrangements while making use of Singapore’s loan safe haven transfer pricing provisions.
- Structuring transfer pricing for offshore intangible licensing companies and structuring a royalty fee arrangement from a US subsidiary to its foreign parent.
- Analyzing cost center alternatives as part of a taxpayer’s transfer pricing cost structure, all being part of globally consistent pricing.
- Developing comparative services approaches for professional services companies.
- Structuring agency relationships to take advantage of the independent agency - dependent agency permanent establishment tax disparity.