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Transfer Pricing

As the economy has turned global, transfer pricing issues are on the rise. Transfer pricing refers to pricing arrangements between related parties or entities. Transfer pricing includes transfers of intellectual property, tangible goods and services and financing transactions.

It is clear that tax authorities around the world have become much more aggressive in conducting transfer pricing audits. The proposed adjustments from these tax authorities in the transfer pricing area represent the biggest dollar adjustments. This poses significant risks for companies engaged in the global economy.

While the largest multinationals in the world can afford to pay big firm fees to resolve its transfer pricing issues, the mid sized and smaller sized businesses struggle to stay compliant with transfer pricing issues.

This is where we feel we can help. The tax attorneys at Sim & Record, LLP have enormous experience in the area of transfer pricing. Our attorneys have represented some of the largest corporations in the world resolve its transfer pricing issues, including using APAs to resolve large tax audit and back tax issues.

With the growing scrutiny by tax authorities in regard to transfer pricing arrangements established by related entitles, we can assist your company in the development of tax-efficient structures that help increase compliance with legal requirements, prepare for rapid audit response, resolve transfer pricing disputes and decrease transfer pricing exposure in future periods. We can assist your company with

  • Advance Pricing Agreements (APAs)
  • Tax controversies and dispute resolution using either the APA or Competent Authority Assistance under various Tax Treaties
  • Documentation and compliance planning.

We have represented the largest corporations in the world in regard to transfer pricing issues. We have also assisted these multinationals enter into satisfactory APAs. The attorneys at Sim & Record were one of the first attorneys to utilize APAs to resolve back tax liabilities by use of rollbacks.

We offer big firm sophistication and experience at affordable prices.