Transfer pricing is one of the most challenging areas of international tax today. Multinational companies that conduct related-party transactions across borders use transfer prices to determine the value of products, services, intangible assets (i.e. rights, trademarks and designs), cost sharing/cost contribution payments, and financial instruments. Tax authorities worldwide are conducting increasingly skilful audits of corporate taxpayers to ensure compliance with the arm’s length principle, and to control presumed base erosion and profit shifting practices. Transfer pricing legislation and guidelines differ between countries, and are presently in a state of change at the country level and at multilateral institutions like the Organization for Economic Cooperation and Development (OECD), the United Nations, and the European Union.
We have extensive experience delivering services in a globally coordinated and locally informed way. In addition to our U.S and Mexico transfer pricing resources, we also work cooperatively with Alliance Partners to deliver transfer pricing services to multinational companies.