Principal and Transfer Pricing leader Will James was recently featured in an article by The Bureau of National Affairs, speaking on the effect that new international tax laws may have on tax-exempt organizations under the BEPS initiative.
Transfer pricing refers to the pricing of goods, services or intangibles within a multinational organization, particularly in regard to cross-border transactions.
The vast majority of global trade occurs between related-party entities. As global trade increases, companies are confronted more and more with complex issues associated with intercompany pricing. This is compounded because many countries have specific transfer pricing legislation, and the tax authorities within those countries aggressively pursue transfer pricing adjustments. It is no wonder transfer pricing is often listed as the single most important international tax issue facing multinational companies.
Whether your intercompany pricing issues involve the sale of goods, the provision of services, the transfer of intangible property or cross-border financing, BKD’s experienced transfer pricing individuals are positioned to provide a full range of transfer pricing services. Our solutions take into account:
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
Most countries 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.
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.
Comparables Benchmarking Studies
The successful resolution of any transfer pricing inquiry often rests on the validity of a taxpayer’s comparables. BKD has access to numerous global comparables databases to assist in the development of arm’s-length ranges for all types of intercompany transactions involving tangible goods, intangible property, services and financing arrangements.
Base Erosion and Profit Shifting (BEPS) Readiness Review
The OECD’s Action Plan on Base Erosion and Profit Shifting (BEPS) will require multinational enterprises to revisit and potentially alter their international tax structures and transfer pricing practices. BKD’s BEPS Readiness Review assists multinationals in assessing their compliance with the evolving BEPS initiatives and provides recommendations for planning opportunities.
BKD offers cost-effective transfer pricing assistance based on an understanding of your business. Through BKD’s membership in Praxity, AISBL and TPA Global, we are able to draw upon transfer pricing professionals worldwide to serve the dynamic needs of multinational clients.