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Transfer Pricing

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The experts at True Partners Consulting relish the challenge of guiding clients through the complex process of transfer pricing. Our world-class tax and economic advice is accessible across the globe—either through our U.S. practice, or through our affiliated firms in more than 80 jurisdictions worldwide.

In the U.S., we help clients to comply with the arm’s-length standard under Section 482 of the Internal Revenue Code. This requires transactions with foreign related parties to be priced consistently with transactions between unrelated parties. The burden of proof is placed squarely on the taxpayer; IRC Section 6662 requires that compliance be documented contemporaneously with tax returns.

Outside the U.S., our client advocacy is based on the relevant jurisdiction’s documentation requirements—however extensive they may be. Most industrialized nations have enacted rules similar to IRC Section 482.

Our services include:

  • Prospective planning advice on the transfer prices companies use in cross-border transactions
  • Studies documenting compliance with IRC Section 6662, or with similar global, regional, and local guidelines and regulations
  • Valuation of intangibles with respect to licensing, cost-sharing, royalties, and transfers of such intangibles
  • Supportive audit defense with respect to proposed adjustments
  • ASC 740 support and analysis
  • Economic analyses related to international, state, and local restructuring transactions.