As of late,Recently, the risk of international companies being audited for transfer pricing has increased substantially throughout the world, and especially in the United States. The current US regulations require that all companies with related-party transactions are required to compile “reasonable and full” documentation of arm’s-length pricing prior to filing annual income tax returns . Our seasoned tax professionals can thoroughly analyze, evaluate and document your methodology for determining the transfer pricing of products, services and intellectual property transferred between or among your related parties. We provide reports that meet the transfer pricing documentation required by the IRS.
For the companies looking for a confidence in the future on transfer prices and related taxable income, we strongly recommend clients to secure the Advance Pricing Agreement (“APA”) between IRS and the taxpayers and IRS or or among multiple other taxing authorities and the taxpayers. There are many advantages of securing an APA for multi-national companies. An APA reduces the risk of double taxation, saves costly litigation expenses, eliminates the hassle of transfer pricing audits, and even resolves the old burdensome tax dispute with the IRS or with other taxing authorities. Not only our experts have the most hands-on APA experience and in-depth knowledge of all aspects of APA, but also our senior staff can provide the APA service to our clients in person at any time.