Transfer Pricing Services
Transfer pricing is the highest risk tax issue facing multinational companies today. Between aggressive government audits and documentation requirements, transfer pricing issues have dominated the news media with significant penalties to both large and small multinational taxpayers. FJV has specific and unique transfer pricing experience that we look forward to sharing with you. This includes our Founder, Frank J. Vari, as the leader of the transfer pricing team that successfully completed the very first U.S. Small Taxpayer Advance Pricing Agreement with the IRS for a Japanese heavy equipment manufacturer.
Risk
Transfer pricing involves the setting of “arm’s length” pricing for almost every cross-border transaction including tangible goods, intangible property, services, royalties, and loans. When set against a backdrop of global tax authorities competing against each other for taxable revenue it is easy to see how transfer pricing touches every multinational business, both large and small, and how every transaction can trigger a potential tax liability and/or penalty.
Strategic Transfer Pricing Services
FJV’s Strategic Transfer Pricing Services is your competitive advantage.
FJV consistently delivers business tax savings and value through our strategic transfer pricing services. Our extensive transfer pricing planning experience allows us to coordinate the facts of your business with the laws and regulations of the countries where you do business in a way that both reduces risk and increases tax savings. This becomes your competitive advantage.
Our strategic transfer pricing services include:
- Strategic design and implementation of U.S., international, and U.S. State & Local transfer pricing strategies
- Intangible property migration and cost sharing arrangements
- Global supply chain planning
- Merger and acquisition due diligence and acquisition integration/merger strategies
- Base Erosion Anti-Abuse Tax (BEAT)
- Global Intangible Low-Tax Income (GLTI)
- Foreign Derived Intangible Income (FDII)
- Post-reform international intangible asset/intellectual property tax planning
Compliance
Today, almost every country has their own set of transfer pricing rules and documentation requirements that are constantly changing. Even the most skilled taxpayers have difficulty maintaining compliance with these complex rules. FJV has significant experience helping both large and mid-sized companies with transfer pricing compliance services.
Our transfer pricing compliance experience includes:
- U.S., Global, and local country specific transfer pricing documentation
- Internationally coordinated transfer pricing documentation
- Reporting of intercompany transaction for both BEPS and FATCA purposes
- Coordination of transfer pricing strategies with VAT, GST, and Customs pricing policies
- Transfer pricing reporting for U.S. GAAP, IFRS, and local country GAAP including ASC 740 and FIN 48
Audits & Disputes
Transfer pricing is not only one of the most contested issues on a worldwide basis but it is also amongst the most difficult to defend. FJV has over 25 years of helping both U.S. and non-U.S. taxpayers successfully defend complex transfer pricing audits on a global basis.
Our transfer pricing dispute resolution experience includes:
- Support from audit initiation through high court legal proceedings
- Local country legal and tax authority representation
- Competent Authority (“CA”) representation
- Advance Pricing Agreements (“APA”)
See our Representative Projects
Call us today at 800-685-2324 to discuss how we can assist with your global transfer pricing needs or request a consultation online and we'll contact you shortly.