Transfer pricing issues are critical to multinational companies, often magnified even further due to increased attention from the press and tax authorities. Therefore, it is essential to have the necessary documentation to support your intercompany agreements. We offer a range of documentation services, which can help provide assurance that companies’ intercompany transactions meet the arm’s length standard. We provide documentation services related to the following:
 

  • Financial transactions (IRC Section 482.2)
  • Tangible Property (IRC Section 482.3)
  • Intangibles (IRC Section 482.4)
  • Cost sharing arrangements (IRC Section 482.7)
  • Services (IRC Section 482.9)

 

In addition to U.S. documentation requirements pursuant to Section 482 of the Internal Revenue Code, we deliver documentation support for other countries and reports that conform to standards promulgated in the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.
 

We have the experience, resources and analytical capability to provide robust documentation for complex transactions, such as Cost Sharing Arrangements (CSAs). CSAs require a rigorous approach to determine what the cost sharing percentages and platform contribution payment(s) should be between the controlled parties. 

 

Our seasoned professionals are well-versed in the analysis and the valuation of intangible assets, using numerous databases to assist with benchmarking. In addition, we have earned a specialty designation in this area and teach classes on intellectual property (IP) valuations for the American Society of Appraisers. References are available upon request.

 

For more information, please contact:

Bill Johnston

Keith Smith