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Transfer Pricing Services
Every multinational enterprise (MNE), regardless of its size, must deal with the complexities of transfer pricing issues. Making sound business decisions regarding transfer pricing goes beyond complying with tax rules and reacting to audits. Developing a comprehensive transfer pricing strategy involves a combination of planning and compliance to meet operational and business objectives.
FTI's Transfer Pricing Services (TPS) practice, comprised of senior professionals with "Big 4" backgrounds and decades of government and private sector experience, offers a reliable and effective independent alternative for dealing with your transfer pricing issues. Our services include:
Strategic Planning
Through a review and modification of intercompany relationships and pricing of goods, MNEs can judiciously optimize income in order to meet immediate operational and business objectives as well as prepare for future strategic cash needs through transfer pricing planning. TPS provides MNEs with effective and reliable solutions with a client focus, which begins with a review of intercompany transactions and a feasibility analysis to determine what solutions may be effective in meeting our clients' objectives. TPS can modify the pricing of goods to redirect cash by restructuring functions and risks among the members of an MNE; determining appropriate royalty rates for technology, marketing, or other intangibles; creating cost sharing arrangements; and valuing and transferring intangibles.
Intangible Property Valuation
In recent years, transfer pricing issues surrounding intellectual property have become a major focus for MNEs and tax authorities alike. Consolidating IP ownership or sharing foreign and domestic benefits of IP ownership can aid in achieving tax planning and operational goals. TPS can assist by determining appropriate royalty rates for technology, marketing, or other intangibles, creating cost sharing arrangements, and developing appropriate and defensible valuations related to the intercompany transfer or acquisition of intangibles.
Advance Pricing Agreements
MNEs facing the risk of economic double taxation arising out of inconsistent tax authority approaches to their transfer pricing can achieve certainty of treatment for up to five years by creating a voluntary and cooperative process with the IRS and other tax authorities. The Advance Pricing Agreement (APA) process is designed to resolve potential transfer pricing issues in a cooperative manner with the U.S. and/or foreign tax authorities. In some cases the APA process can also be used to resolve existing tax audits. TPS represents clients through the entire APA process from pre-filing, to development of the economic and legal justification for the client's proposal, through negotiation of the final terms of the agreement with the tax authorities.
Audit Defense
Forward-thinking MNEs proactively manage the transfer pricing audit process by engaging an experienced audit defense team at the first sign of difficulty. TPS can develop appropriate strategies to respond to tax authority challenges, assist in responding to information requests, provide expert economic testimony as well as assess alternative dispute resolution options.
Compliance
MNEs can reduce the likelihood of costly and unpleasant legal challenges by creating transfer pricing documentation that complies with legal and regulatory requirements in jurisdictions where audit risk is material. TPS works with clients to develop proper documentation that reduces the risk of transfer pricing adjustments and penalties.
Economic Services
TPS provides economic services that are designed to adapt to each client's needs. We dedicate significant resources to ensure that we are providing our clients with the most progressive and appropriate economic services available. Our economic service offerings include strategic and competitive analysis, economic impact studies, and tax benefit analysis provided under the Foreign Sales and Leasing Income provisions of the Extraterritorial Income Exclusion Act.
For more information on transfer pricing services:
TPSinfo@fticonsulting.com
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