Transfer Pricing Services
Transfer pricing can be one of the most significant issues facing domestic and multi-national corporations conducting cross-state or international transactions. Regulations vary by jurisdiction and transaction type, and tax authorities worldwide are keen on ensuring their fair share of tax revenue. The risk of being challenged on transfer pricing practices is an all-too-present reality.
While the penalties can be steep for organizations failing to fulfill the required standards, transfer pricing represents an opportunity. RSM believes transfer pricing can be a tool to help manage your tax exposure, maximize business opportunities and, where appropriate, identify your optimal tax structure.
RSM offers transfer pricing services for every step of growing your business. Our services include:
IRS arguments on appeal provide useful insight for taxpayers into IRS consideration of transfer pricing cases.
New IRS guidance on country-by-country (CbC) reporting highlights useful information and additional resources.
Tax strategy implemented in 1999 may lack economic substance to support subsequent shift of functions and profits.
On May 19, 2017, Chevron Australia Holdings Pty Ltd. sought special leave to appeal to the High Court of Australia the Full Federal Court’s decision...broader discussions among multinational enterprises on cross-border intercompany financing arrangements under Australian and other jurisdictions’ transfer pricing rules continue as taxpayers face uncertainty.