Transfer Pricing

Transfer pricing is one of the most significant tax issues facing multinational corporations. The expanding reach of multinationals, combined with increased tax authority scrutiny and the growing number of countries that have joined the United States in examining and regulating intracompany activity, has made it impossible to address transfer pricing issues without expert guidance. New IRS regulations affect the pricing of intracompany services and cost-sharing arrangements, and an increased focus on intangibles as a means to transfer profits creates increasingly difficult valuation issues.

We have extensive experience assisting clients in numerous aspects of these matters, including litigation consulting and expert testimony, and have supported clients in some of the major transfer pricing litigations of recent years, including the GlaxoSmithKline-IRS dispute.

We can call upon the experience of our staff and affiliated experts across a range of practice areas that integrate with transfer pricing issues. Our experts have brought innovative approaches to solving a number of tax and transfer pricing issues in litigation, including audits, appeals, and competent authority negotiations. We have also assisted various tax authorities around the globe in matters related to transfer pricing.

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