A Swiss securities trading company operating a US office had previously engaged a US law firm to review their transfer pricing arrangements. The client’s US accounting firm recommended that the company obtain a second opinion of their transfer pricing arrangements and WTP Advisors was engaged to undertake a transfer pricing review. We reviewed the transfer pricing planning and documentation and analyzed the division of functions, risks and income between the United States and parent entity. We identified weaknesses and exposures in the tax planning and transfer pricing documentation and recommended that the client alter the characterization of earnings and distributions from the US subsidiary.
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