Transfer Pricing and Review of Cross-border Transactions

PRIMARY CONTACTS: Mary D. Richter CPAMarko Zivanov

As with many other countries,U.S. tax rules strive to ensure that taxpayers with common ownership are using “arm’s length” pricing when buying and selling products, services, and intangibles to one another.

Essentially, “arm’s length” pricing means ensuring that related entities are paying their related counterparts the same prices for goods and services as they would be paying an unrelated third party. Each intercompany transaction must be separately accounted for in a company’stransfer pricing policy, whichasrequired by the U.S. Tax Code, must be maintained as contemporaneous documentation. 

We present practical, customized solutions to our clients’ unique transfer pricing needs. Theseservicesinclude: 

  • Audit support 
  • Functional analysis 
  • Analysis of comparable companies 
  • Transfer pricing studies and annual updates 
  • Documentationofcomparable companies andassessments, in line with IRS and OECD requirements 
  • Transfer pricing planning 

We also work with specialists to include transfer pricing analysis for local countries, in conjunction with U.S. reporting. 

About Schneider Downs Tax Advisors 

With one of the largest regional tax practices in the country, Schneider Downs Tax Advisors’ personal focus on clients and in-depth understanding of current issues ensures that clients are complying with tax filing requirements and maximizing tax benefits. Our industry knowledge and focus ensures delivery of technical tax strategies which can be implemented as practical business initiatives. Learn more at www.schneiderdowns.com/tax-services.

case studies

 
                                    Company impacted by ransomware.
big problem:
Company impacted by ransomware.
big thinking:
Restore system on-site and avoid six-figure ransom.
 
                                    Inefficient tax credit realization.
big problem:
Inefficient tax credit realization.
big thinking:
Identified a $900,000 tax credit, nearly twice as much as prior years.

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