We assist multinational companies with transfer pricing consulting services
We do this to to reduce risk inherent in their transfer pricing positions, comply with country documentation requirements to explain the purpose, substance and reasoning behind each transfer price, and resolve and avoid disputes with tax authorities. Our transfer pricing consulting services are delivered in a bespoke manner specific to each client’s business and circumstances in the following ways:
Planning, amending, or restructuring international related-party transactions
When companies want to know if a transaction is being carried out at arm’s length, or could be changed to better match current business conditions, we are called in to assist. Our task is to develop and implement new policy, and model that policy over the short or long term. Often we revise existing policy and then transfer knowledge to management so policies are understood, practical, compliant, and aligned with business operations.
Identifying and managing transfer pricing risk positions
We assist companies to find, understand, manage, communicate, and resolve transfer pricing risk that arises as part of tax provision reviews or in M&A transactions.
Managing and resolving transfer pricing audits or examinations (working with attorneys and/or accountants)
We use our long experience in transfer pricing controversy, a sharp eye for detail, and economic analysis to help shape a controversy strategy, communicate effectively with tax authorities, and advocate for a reasoned, arm’s length outcome at any stage of a dispute with a tax authority.
We help companies comply with annual Canadian and U.S. annual transfer pricing documentation requirements
After the planning is implemented and the actual transaction outcomes are known, we coordinate our activities with accounting firms that perform audit and review engagements and prepare corporate tax returns and international transaction reporting forms, and with lawyers and attorneys that draft and maintain intercompany agreements. Our documentation is bespoke, unfluffy, and covers the important elements of each material transfer pricing position to make the company’s position clear and to set the stage for an efficient tax authority review.
Accessing tax treaties to request relief from double taxation
Our transfer pricing consulting services also include resolving a double tax issue using a Mutual Agreement Procedure.
Technical and administrative requests for an APA
Achieving certainty using a bilateral Advance Pricing Arrangement between tax authorities requires both technical and administrative know-how and experience. We have both, and use our expertise to work with lawyers and attorneys to obtain long-term certainty for companies over high-risk transfer pricing positions.
