Transfer Pricing

PRIMARY CONTACT: Mary Richter CPA (Pittsburgh)

We work with our clients to present practical solutions to transfer pricing issues.

In order to avoid income-shifting to lower-tax entities or jurisdictions, U.S. tax rules strive to set prices between controlled taxpayers using "arms-length" pricing (what unrelated parties would pay). This arm's-length standard applies to sales of products and services, as well as sales and use of intangibles (trade names, patents, know-how, etc.), essentially all transactions between related parties. Each type of intercompany transaction must be separately accounted for in a company's transfer pricing policy.

The U.S. Tax Code requires that the taxpayer maintain contemporaneous documentation that supports its transfer pricing policy. Other countries have similar rules.

Types of transfer pricing services:

  • Audit support
  • Functional analysis
  • Comparables analysis
  • Documentation compilation and assessment
  • Transfer pricing studies and updates

case studies

Ransomware attack halted a global manufacturer's operations.
big problem:
Ransomware attack halted a global manufacturer's operations.
big thinking:
Recover and secure the system – fast – save $1 million in ransom.
High tax burden for family-owned franchisor.
big problem:
High tax burden for family-owned franchisor.
big thinking:
Comprehensive planning for a 15% tax reduction.

our thoughts on

Postcard from Prime Global’s International Tax Session
Taxation Implications for Foreign Nationals Working in the United States, in a Nutshell – PART 1
International Trade Deal Creates the World’s Largest Trading Bloc
EU Provides Guidance on the New E-Commerce VAT Rules
International, Tax BY Vicky Lu
IRS Releases New Proposed Partnership Schedules (K-2 and K-3) for International Tax Reporting

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contact us

Map of Pittsburgh Office

One PPG Place, Suite 1700
Pittsburgh, PA 15222
p:412.261.3644     f:412.261.4876

Map of Columbus Office

65 East State Street, Suite 2000
Columbus, OH 43215
p:614.621.4060     f:614.621.4062

Map of Washington Office
Washington, D.C.

1660 International Drive, Suite 600
McLean, VA 22102