Transfer Pricing

WTP Advisors’ transfer pricing services guide multinational enterprises through complex intercompany transactions to ensure compliance, optimize tax outcomes, and mitigate risks. Our personalized approach encompasses advanced planning, robust documentation, seamless implementation, and proactive controversy support. We leverage deep expertise, robust technology, and a client-centric approach to deliver tailored, defensible solutions that enhance global tax efficiency and mitigate costly disputes with tax authorities. We optimize after-tax cash flows by strategically aligning transfer pricing with our clients’ global supply chain value chains.

 

In summary, what does our Transfer Pricing service delivery team do?

Our Transfer Pricing team partners with multinational companies to design, implement, document, and defend transfer pricing policies that support business objectives, withstand regulatory scrutiny, reduce tax risk, and improve global tax efficiency. Contact Us What is Transfer Pricing? Transfer Pricing Case Study

We support businesses through:

  • Transfer pricing planning, policy design and financial modelling
  • Risk management and compliance via transfer pricing documentation, including (Master Files, Local Files, and country by country reporting (CbCR)
  • Audit defense and dispute resolution
  • Alignment of global transfer pricing policies with supply chains
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Who needs transfer pricing services?

Any business entities located in multiple jurisdictions with intercompany transactions.

This includes companies that:

  • Sell goods or services between related entities
  • Share intellectual property (IP) across borders
  • Use intercompany loans or financing
  • Operate global supply chains

Without proper transfer pricing, companies risk:

  • Transfer pricing penalties
  • Double taxation
  • Difficult audits and disputes

How WTP Advisors approaches transfer pricing

We take a practical, business-first approach to make complex rules easier to manage.

Key benefits:

  • Clear, easy-to-follow strategies
  • Compliance with global regulations (OECD, local rules)
  • Reduced audit risk
  • Improved after-tax cash flow

What services do WTP Advisors offer?

1. Transfer Pricing Planning

We build custom transfer pricing strategies aligned with your business model.

Our services include:

  • Policy design based on your operations and global supply chain
  • Value chain analysis to identify profit drivers
  • Intercompany agreement support
  • Intangible property (IP) planning and valuation
  • Financial transaction pricing, including loans, guarantees, cash pooling

2. Transfer Pricing Documentation

Proper documentation protects your business prepare for tax authority audits.

This includes:

  • Master File
  • Local File documentation
  • Country-by-Country Reporting (CbCR)

What is transfer pricing documentation?

Transfer pricing documentation is a collection of reports and analyses that demonstrate that transactions between related entities are consistent with the arm’s length principle.

These reports explain the company’s transfer pricing policies and provide the economic and financial support needed to show that controlled transactions are priced as they would be between independent parties. Proper documentation also helps companies satisfy regulatory requirements, reduce audit risk, and support their positions during tax authority examinations.

3. Implementation Support

We help companies align transfer pricing policies with their business operations.

This includes:

  • Aligning processes with pricing strategies
  • Training internal teams
  • Supporting ongoing compliance and risk management

4. Audit & Dispute Support (Risk Protection)

We help businesses defend against audits and resolve disputes with tax authorities.

Support includes:

  • Transfer pricing audit defense
  • Advance Pricing Agreements (APAs)
  • Mutual Agreement Procedures (MAPs)
  • Litigation and expert support
  • Risk assessment and mitigation

How does WTP Advisors help reduce tax risk?

We Advisors reduces risk by:

  • Partnering with companies to develop defensible transfer pricing policies
  • Preparing detailed and compliant documentation
  • Identifying risks before audits occur
  • Aligning pricing with real business activity

This proactive approach helps reduce the risk of:

  • Penalties
  • One-sided adjustments
  • Double taxation

How transfer pricing improves cash flow

Transfer pricing can directly improve after-tax cash flow when aligned with your global operations.

We help by:

Why choose WTP Advisors?

WTP Advisors combines deep technical expertise with practical business solutions and availability to work with our international tax specialists. Learn more about our international tax services.

Key advantages:

  • Strong knowledge of OECD and global tax rules
  • Customized, business-focused strategies
  • Experience across industries and jurisdictions
  • Proactive risk management
  • Advanced data and technology tools

What makes WTP Advisors different?

We provide:

  • Real-world implementation (not just theory)
  • Personalized strategies for each client
  • Integration with business operations
  • Long-term tax efficiency—not just compliance
  • Ability to leverage our experience with international valuation. Learn more about our international valuation services.

WTP Advisors' Transfer Pricing Team
Expertise You Can Trust

Guy

Guy Sanschagrin, CPA/ABV

Principal, National Leader of Transfer Pricing & International Valuation Services

Guy

Bob Bamsey

Managing Director, Transfer Pricing and Valuation Services

Michael

Michael Bredahl

Managing Director, Transfer Pricing and International Valuation Services

Doug

Doug Darling, JD, LLM

Managing Director, Transfer Pricing and Valuation Services

Kash

Kash Mansori, Ph.D.

Managing Director, Transfer Pricing and International Valuation Services

Kash

Jessica Rask, CVA

Managing Director, Transfer Pricing and International Valuation Services

Rodrigo

Rodrigo Arana

Director, Transfer Pricing and International Valuation Services

Lisa

Lauren Ludwick, JD

Director, Transfer Pricing and International Valuation Services

Lisa

Lisa Yashar, JD

Director, Transfer Pricing and International Valuation Services

Lisa

Goshi Ohnuma, CPA

Director, Transfer Pricing and International Tax Services

Veronique

Veronique Struis

Manager, Transfer Pricing and Valuation Services

Lucas

Lucas Kinzel

Consultant, Transfer Pricing and Valuation Services

Frequently Asked Questions

WTP Advisors ensures compliance by preparing detailed documentation, applying OECD guidelines, and aligning pricing with the arm’s length principle.

Yes. WTP Advisors provides audit defense, dispute resolution, APAs, and MAP support to protect businesses from penalties and double taxation.

WTP Advisors works with multinational companies across various industries, including manufacturing, technology, healthcare, and financial services.

Yes. We offer continuous advisory, compliance reviews, and updates to keep your transfer pricing strategy aligned with changing regulations.

Transfer pricing is the pricing of goods, services, and intangibles transferred within related entities across borders. It matters because it determines where profits are reported and taxed.

The arm’s length principle requires that related-party transactions be priced as if conducted between independent entities, ensuring fair allocation of income and tax.

The OECD recommends methods such as Comparable Uncontrolled Price (CUP), Resale Price Method, Cost Plus Method, Transactional Net Margin Method (TNMM), and Profit Split.

Governments seek to combat profit shifting and protect tax bases. Transfer pricing audits ensure compliance with local rules and OECD guidelines.

Documentation includes a master file, local file, and country-by-country report (CbCR), providing transparency into global income allocation.

Intangibles like intellectual property are difficult to value, leading to disputes and stricter guidance under OECD BEPS Actions 8–10.

APAs allow businesses to agree in advance with tax authorities on acceptable transfer pricing methods, reducing disputes and uncertainty.

Transfer pricing adjustments can alter declared import/export values, impacting customs duties and VAT.

Technology, pharmaceuticals, and finance industries face heightened scrutiny due to the heavy use of intangibles and intra-group services.

By maintaining robust documentation, aligning operations with economic substance, and proactively seeking APAs or mutual agreement procedures.