Our transfer pricing successes:

• Successfully defended multinational taxpayers against IRS economist and international examiner transfer pricing attacks, avoiding all adjustments and penalties.
• Developed in-house comparables transfer pricing strategies for our clients, avoiding the need for the company to rely on public databases – and database fees.
• Substantiated reinvoicing activities in a tax haven relationship between two high-tax jurisdictions. Successfully substantiated DISC – FISC subsidiary structure to substantiate FISC transfer pricing activities.
• Successfully defended foreign-based multinational taxpayers against IRS attempts to restructure SIC/NAICS categorization, avoiding all adjustments and penalties.
• Successfully defended major multinational corporations against IRS documentation claims, avoiding all adjustments and penalties.

What we are doing now in transfer pricing:

• Structuring Singapore/US coordinating service arrangements while making use of Singapore’s loan safe haven transfer pricing provisions.
• Structuring transfer pricing for offshore intangible licensing companies and structuring a royalty fee arrangement from a US subsidiary to its foreign parent.
• Analyzing cost center alternatives as part of a taxpayer’s transfer pricing cost structure, all being part of globally consistent pricing.
• Developing comparative services approaches for professional services companies.
• Structuring agency relationships to take advantage of the independent agency - dependent agency permanent establishment tax disparity.