International expansion, mergers and acquisitions are taking U.S.-based companies into foreign countries and vice-versa. Transferring goods, services, intangible assets and capital among related entities requires the same pricing that would have resulted from an “arm’s length” transaction with an unrelated entity. Transfer pricing rules vary by country and are evolving quickly as taxing authorities worldwide digest the policy recommendations made by the OECD as part of its Base Erosion and Profit Shifting (BEPS) project.
Through BEPS actions, the OECD is trying to build global consensus around enhanced transparency and proper alignment of profit outcomes with economic substance as it relates to related party transactions. The evolving policy changes being evaluated by local countries are expected to increase the burden on taxpayers to demonstrate compliance with the arm’s length standard and to increase the amount of transfer pricing audit inquiries and controversies.
Transfer pricing planning and documentation can help companies meet their growing compliance obligations, optimize their overall effective tax rate, mitigate their risk of double taxation and manage their transfer pricing audit risk. CBIZ MHM’s transfer pricing services team can help develop arm’s length transfer pricing policies and prepare the necessary transfer pricing documentation companies are required to maintain.
Whether you’ve been asked to produce a transfer pricing study because you’re being audited or your company would like to optimize your current policy, CBIZ can assist. Our specialists work with companies worldwide to form transfer pricing strategies that comply with domestic and international transfer pricing regulations. Through our membership and active participation in Kreston International, we can also ensure your transfer pricing policies are in compliance with foreign country tax law, no matter where your business may take you.
Our core services include:
- Transfer pricing benchmarking studies to develop and/or optimize transfer pricing methodology(s)
- Transfer pricing documentation studies to meet U.S.- and foreign-based documentation requirements
- Analysis and modeling of intercompany services charges
- Benchmarking searches for royalty and license agreements, intercompany interest rates, and comparable company samples
- Valuation of intangible property and evaluation of IP migration strategies
Contact us for more information.