Transfer Pricing
Transfer pricing is one of the most significant tax issues facing multinational corporations.
- The growing number of countries joining the United States in examining and regulating intracompany activity make it impossible to address transfer pricing issues without expert guidance.
- An increased focus on intangibles as a means to transfer profits creates increasingly difficult valuation issues.
- New IRS regulations affect the pricing of intracompany services and cost-sharing arrangements.
- The expanding reach of multinationals, combined with increased tax authority scrutiny, requires a comprehensive approach to transfer pricing issues that may span dozens of countries and legal entities.
Analysis Group has extensive experience assisting clients with situations in which tax authorities challenge intracompany prices, including audits, appeals, competent authority negotiations, and litigation. We have also assisted various tax authorities in matters related to transfer pricing.
Litigation consulting and expert testimony are among Analysis Group’s greatest strengths. We have been involved in some of the major transfer pricing litigations of recent years, including the GlaxoSmithKline-IRS dispute, and can call upon the experience of our in-house 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.