Transfer Pricing

Transfer Pricing

Proactive planning versus reactive compliance.

WTP offers a multidisciplinary approach to transfer pricing that exploits our strengths in data management and quantitative analytics – this integrated approach encourages strategic planning instead of merely achieving compliance.

We bring a depth of experience to the table that instills great confidence. You’ll never deal with entry-level staff, only senior professionals with broad industry and Big Four transfer pricing expertise – able to integrate transfer pricing into financial, management and statutory reporting, quickly and efficiently.

We also never forget that delivering the goods is a team effort – our people work closely with your tax, finance and operations personnel to implement only the solutions that dovetail smoothly with your goals and objectives.

Transfer pricing remains the single most important tax issue confronting multinational enterprises.

The arm’s length principle, as set out in Article 9 of the OECD Model Tax Convention and in the U.S. tax code is the standard to which most countries adhere in judging the correctness of the pricing of transactions between commonly controlled parties. Despite the international consensus on this principle, however, taxpayers would be well advised to understand that differences in transfer pricing approaches, in economic theory and in actual results can vary significantly even among countries adhering to this principle. Consequently, taxable income reported from cross-border transactions may result in disagreements between tax authorities as well as disputes between tax authorities and taxpayers.

WTP is a global leader in helping multinational enterprises develop transfer pricing strategies and documentation that will identify potential conflicts, exploit opportunities and minimize tax risks associated with cross-border transactions. 
 
As summarized in the attached case studies, WTP has an experienced multi-disciplinary team of transfer pricing professionals who assist our clients in identifying tax efficient structures and transactions and in developing and implementing sustainable tax strategies supported by global documentation. WTP also offers tax audit and litigation support capabilities to assist multinational enterprises in balancing and responding to the increased scrutiny of tax administrations around the world. The potential disagreements between and among tax authorities represent a major tax risk confronting multinational enterprises today, and necessitate a global approach to transfer pricing planning and compliance rather than the traditional country-by-country approach.

 


Read our Transfer Pricing case studies to learn how WTP Advisors has helped our clients and to gain insight into how our global capabilities can help your business.


 

Our Transfer Pricing services include:

  • Tax Planning and Design
  • Risk and Opportunity Analysis
  • US, OECD, Local Documentation
  • Global Audit Support
  • Global Litigation Support
  • Post-merger Integration
  • Advance Pricing Agreements
  • Competent Authority Relief

 

Contact us to learn more about our services.  

Global Contact Guy Sanschagrin

Guy Sanschagrin
Principal
952-955-6677
guy.sanschagrin@wtpadvisors.com

WTP InsightsAmazon wins $1.5 billion transfer pricing case against the IRS

Apr 04, 2017

Major developments for taxpayers in Indonesia

Jan 30, 2017

Tax Alert: Exchange of tax rulings, a Dutch practice update

Aug 24, 2016

Tax Alert: IRS Targeting Small and Mid-sized Companies for Transfer Pricing Audits

May 16, 2016

Tax Alert: Australia’s proposed Diverted Profits Tax outlined

May 10, 2016

Tax Notes International - Assessing Value Creation for Transfer Pricing

Mar 28, 2016

Tax Alert: IRS Proposes Country-by-Country Reporting Rules for 2017

Dec 22, 2015

Tax Alert: Chevron Australia Holdings Pty Ltd v. Commissioner of Taxation decision released

Nov 19, 2015

Tax Alert: More Dutch Transfer Pricing requirements proposed

Sep 22, 2015

Questions Remain on BEPS, U.S. Model Treaty Changes

Aug 28, 2015

Australia – new tax integrity measures announced

May 29, 2015

OECD Cost Contribution Arrangements Draft Emphasizes Value

Apr 30, 2015

Philippines' tax authority looks at transfer pricing as one of the priority programs for 2015

Mar 16, 2015

Kash Mansori, Ph.D., Joins WTP Advisors' Transfer Pricing Practice

Feb 04, 2015

OECD Issues Profit-Split Method and Commodity Transactions Drafts

Dec 17, 2014

Footnote, the publication of the MNCPA - Transfer pricing in the context of international M&A

Sep 09, 2014

Practice Advantage - Transfer Pricing and M&A

Jun 16, 2014

German American Trade - Transfer Pricing: A Critical Tax Management Tool for German Multinationals with U.S. Affiliates

Apr 01, 2013

Transfer Pricing International Journal - Intercompany services and intangibles

Apr 12, 2012

WTP WebinarsOECD Base Erosion and Profit Shifting Plans: What You Need to Know in 2016

WTP Advisors’ Guy Sanschagrin and Quantera Global’s Richard Slimmen Speaking on The Knowledge Group’s Live Webcast, May 11. With growing international attention on multinational corporations avoiding taxes, the Organization for Economic Cooperation and Development (OECD) released its final reports on BEPS in October of 2015. While some of these guidelines won’t go into effect for a few more years; others like the new transfer pricing documentation standards and country-by-country reporting are in full force now. Therefore, it is important for companies to understand the changes, be transparent regarding finances and know how BEPS can impact their organizations.

Transfer Pricing and Valuing International Entities and Global Intangibles

Guy Sanschagrin, WTP’s National Transfer Pricing and Valuation Services Practice leader, will share his perspective on Transfer Pricing and Valuing International Entities and Global Intangibles during the National Association of Certified Valuators and Analysts (NACVA) International Business Valuation Webinar week on September 29, 2016, at 7am Central Time. Webinar week runs from September, 26-September 20, 2016.