Transfer Pricing Solutions

• Planning – Whether entering new markets, restructuring operations or reviewing transfer pricing policies, BKD can help multinationals develop and achieve tax-efficient strategies through transfer pricing planning. Throughout the process, transfer pricing practitioners work with our international and other tax consultants to provide comprehensive solutions.
• Documentation – More than 40 countries—a number that is rapidly rising—require transfer pricing documentation to substantiate a multinational’s intercompany transactions. Failure to maintain the proper documentation can often result in adjustments, penalties and interest. BKD works with clients to help prepare the requisite documentation to help mitigate the risk of transfer pricing adjustments and penalties.
• Dispute Resolution – In the event of an examination, BKD helps work with tax authorities to resolve the dispute. Our team draws on its experience working for tax authorities and on past dispute resolution cases.
• Advance Pricing Agreements – Multinationals can enter into advance agreements on their transfer pricing methodologies with at least one government body to obtain forward clearance and/or resolve past transfer pricing disputes. BKD and our international alliance have experience helping clients obtain these agreements.
• Risk and Opportunity Assessments – BKD provides objective reviews of a client’s current transfer pricing policies and practices and offers guidance and recommendations on how to make them more robust from a retrospective and prospective viewpoint. This enables a subsequent transfer pricing review to be more focused and efficient.
• Intellectual Property Valuation – Valuation of intellectual property for tax purposes is necessary for business reorganizations and tax planning, such as cost-sharing arrangements. BKD understands how valuation of intellectual property for tax purposes can differ from traditional valuation approaches.

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