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

IRS Announces Transition Tax Added to Examination Target List
Treasury Issues Final FDII Regulations
Accounting Relief for Rent Concessions received by International Organizations due to COVID-19
The Impact of COVID-19 on Transfer Pricing Strategies of Multinational Corporations
J5 Tax Chiefs Closing the Net on Global Tax Evasion

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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