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:
The Ninth Circuit has withdrawn its July 24 Altera opinion in favor of the IRS while a reconstituted panel considers the opinion.
IRS’ attempt to re-characterize loan as a distribution from subsidiary’s earnings fails under debt-equity principles.
A guide for multinational corporations regarding country-by-country reporting questions and base erosion profit shifting.
Taxpayers must consider financial statement impact of the unexpected reversal of the full Tax Court decision in Altera.