We assist multinational companies with transfer pricing consulting services
- Reduce risk inherent in transfer pricing positions with support from transfer pricing consulting services,
- 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 bespoke and specific to each client’s business and circumstances:
Plan, amend, or restructure international related-party transactions
Want to know if a transaction is being carried out at arm’s length, or matches new business conditions? We develop and implement new policy, and model that policy over the short or long term. Next, we transfer knowledge to management so policies are practical, compliant, and aligned with business operations.
Identify and manage transfer pricing risk positions
Find, understand, manage, communicate, and resolve transfer pricing risk that arise as part of tax provision reviews or in M&A transactions.
Manage and resolve transfer pricing audits or examinations (working with attorneys and/or accountants)
Using our long experience in transfer pricing controversy, a sharp eye for detail, and economic analysis, we 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.
We help companies comply with annual Canadian and U.S. annual transfer pricing documentation requirements
Our documentation is bespoke and unfluffy. It covers each material transfer pricing position to make the company’s position clear and to set the stage for an efficient tax authority review. We coordinate with corporate tax return preparers, and with attorneys that draft and maintain intercompany agreements.
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 use our expertise to work with lawyers and attorneys to obtain long-term certainty for high-risk transfer pricing positions.
