Business transactions mingled with related parties are subject to the international arms-length price specimen enforced by governmental authorities and taxing jurisdictions worldwide. In the United States, the arms-length standard applies for both federal, and increasingly, state income tax purposes. It is corporal in Sections 482 and 6662 of the Internal Revenue Code (IRC), as swell as the regulations issued there under, related IRC Sections and applicable case law. Our work in this area include preparation of documentation for penalisation protection, economic analysis for advanced pricing agreements (APA), remove pricing planning, and tax controversy support.
Transfer set Consulting
Transfer price for multinationals can be a complicated issue. Productive Pricing can help your team implement practical solutions to mitigate cash flow and address transfer pricing risks globally.
only when stated, Productive Pricing helps companies realize cash savings, manage transfer pricing audit risks and reduce advisor costs by dint of strategic transfer pricing planning. We offer Big-4 accounting besotted transfer pricing expertise, personal service and practical solutions.
wonder where to begin?
As a starting point, we believe in applying these five principles:
Five Principles for Proactive Transfer Pricing counseling
1. Put yourself in the tax potencys shoes.
What would a tax authority want to understand about your intercompany pricing strategy? close to importantly, how would tax authorities from both sides react to local ground operating results? (Not profitable enough, too profitable or conjectural profits?)
2. Explain your transfer pricing approach in plain language.
Avoid raising suspicions with a confusing comment of key facts or analyses.
3. Review your transfer pricing results during the year.
Mid-year changes to intercompany pricing are almost always easier than justifying surprises after...If you want to get a full essay, order it on our website: Ordercustompaper.com
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