Transfer Pricing Solutions and Services
We work to help minimize the risks associated with transfer pricing as well as maximize tax efficiency. Both done well can not only satisfy compliance protocols, but can add significant value to a business.
Transfer Pricing Overview
Transfer pricing deals with the determination of prices charged in transactions between related parties and helps organizations manage how profits are allocated between internal cross-border entities. If you are a multi-jurisdictional organization … if you are engaged in multinational business … if you have cross-border transactions between affiliated entities … if you are considering an acquisition, an IPO, or you are forging ahead into new markets, fulfilling transfer pricing requirements is not just desirable, it is a necessity.
In the U.S., the tax treatment of related party transactions is governed by Internal Revenue Code (IRC) Section 482 and the regulations thereunder. This requires cross-border transactions between related parties to be priced consistently with transactions between unrelated parties. Compliance must be documented contemporaneously with the filing of income tax returns. Without advice from an expert, those taxpayers unfamiliar with transfer pricing rules might miss opportunities to reduce tax and/or be subject to increased taxes or penalties.
Since tax systems vary from country to country, your transfer pricing strategy and policies must be in line with international regulatory standards (such as BEPS, the OECD’s Inclusive Framework on Base Erosion and Profit Shifting), which include transactional independence. This also applies to non-U.S. based companies with operations in the U.S.
Compliance, Reporting, and Documentation
With extensive knowledge of global transfer pricing rules, Echelon delivers the reports and materials needed to satisfy local country regulations, particularly where compliance must be documented contemporaneously with the filing of income tax returns. Our reports are both comprehensive and highly detailed with consideration to defense strategies should an audit occur.
Audit Support, Analysis, Defense/Dispute Resolution
Disputes with tax authorities do happen. And our team will stand by you, helping you to navigate the process, prepare background analysis, and design defense strategies. Our experts have supported clients in a range of businesses, across industries, whether inbound or outbound, with the high-quality documentation needed to avoid unnecessary adjustments and misconceptions that may arise with tax authorities in different countries and tax jurisdictions.
Strategy, Design, and Planning
With complete analysis and an understanding of your company’s business, we can provide transfer pricing structures that aim to reduce tax liability, achieve tax efficiency, maximize your transfer pricing tax structure, and help to minimize the risk of a tax audit. We also partner with tax advisors in other jurisdictions around the world to provide an integrated approach to planning for international investments inside and outside the U.S.
Transfer Pricing Solutions Across Industries
Transfer pricing is relevant to a wide range of companies – and is not confined just to large, multi-jurisdictional concerns. Small companies, start-ups, or companies under common control that may be looking for investment or to engage in an investment transaction all need to consider transfer pricing as part of their overall business strategy. And finally, your industry sector or category of business must be considered.
Echelon serves clients across a wide range of industries and industry sectors. For example:
• Automotive,
• Chemical, and industrial products
• Consumer/luxury goods
• Financial services
• Healthcare
• Hospitality
• Professional services
• Real estate
• Technology
• Telecommunications.
Global Solutions
With extensive knowledge of both U.S. and global transfer pricing rules, and through its close work with other global tax advisors, Echelon can deliver the reports and other materials needed to satisfy local country regulations around the world. Together with our partners, we can provide comprehensive solutions that ensure our clients receive strategic guidance in navigating the complexities of international taxation.
