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TP Minds West Coast
December 6 - 7, 2022
InterContinental Hotel San FranciscoCalifornia, USA

Moss Adams

Profile

Transfer pricing, or the pricing of transactions between affiliates in different tax jurisdictions—also known as intercompany pricing—presents both tax opportunities and financial reporting risks for multinational businesses.

Tax authorities place a heightened focus on transfer pricing to increase revenue, leading to a rise in transfer pricing audits and penalties imposed.

Proactively enacting transfer pricing procedures while working toward compliance can help your business avoid costly audits and lower your worldwide effective tax rate—so you can stay focused on its international growth.

Transfer Pricing Risks and Solutions

All cross-border related party transactions are subject to scrutiny, whether your company has operated subsidiaries in multiple countries for years or you’re setting up your first foreign outpost.

Transactions susceptible to transfer pricing can include:

  • Sales of tangible or physical goods
  • Services
  • Intangibles such as technology, software, or brand names
  • Financing transactions such as loans, cash pooling, and guarantees

Understanding the tax consequences of your transfer pricing decisions can help you comply with tax laws, avoid costly audits, and enhance your tax position.

Our team has the expertise to assist with complex valuations of intangible property, advance pricing agreements and mutual agreement procedures, accuracy-related penalty protection, Organisation for Economic Co-operation and Development (OECD) base erosion and profit-sharing (BEPS) Action 13, and mergers and acquisitions (M&A) due diligence.

We can also assist with studies of less common, often domestic, transfer pricing arrangements such as the arm’s length pricing of treatment charges within a mining operation and stumpage of standing timber. We have experience assisting with pricing between real estate investment trusts (REITs) and taxable REIT subsidiaries, with pricing loan guarantees, and with structuring and determining arm’s length interest rates in cash pool arrangements.

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