Transfer Pricing Planning and Documentation
- Planning intercompany charges for: inventory; licensing of patents, trade names and other intangibles; related party services; intercompany financing and other related party transactions
- Managing and controlling IRS and foreign country tax audits and controversies
- Performing "functional analysis" - ranging from a single product to a comprehensive study on a company-wide basis
- Reviewing and managing economic studies and assessing the quality of comparables
- Reviewing proposed pricing policies and the implementation thereof
- Advice with respect to the level of "documentation" which is appropriate and identifying the transactions which should be studied and documented.
- Advice and planning with respect to "cost sharing arrangements" and "contract R&D" agreements and the implementation thereof
- Drafting and reviewing intercompany contracts, license agreements and other documentation to withstand scrutiny by U.S. and foreign tax authorities
- Assessing whether "periodic adjustments" should be made to transfer prices and/or financial results
- Analyzing foreign tax consequences of changes in pricing policies
- E-commerce transfer pricing
- Evaluating the benefits of entering into an Advance Pricing Agreement
- Tax Treaty "Competent Authority" Assistance (U.S. and foreign-to-foreign)
- State and local tax planning with intangibles
