Intercompany Transfer Pricing

Experienced Washington DC Tax Attorneys

If your company has cross-border dealings with a related party, you probably know that transfer pricing enforcement is a high-profile and big-dollar audit priority for U.S. and foreign taxing authorities. Section 482 of the Internal Revenue Code gives the IRS broad discretion to reallocate income by second-guessing your transfer prices and can make it challenging for taxpayers to overcome such adjustments.

We have extensive in-depth knowledge regarding intercompany pricing issues in the United States, Europe, and Asia from both a planning standpoint and defense standpoint when there is a controversy with the relevant taxing authority. We can provide multinational clients with advice concerning transfers of intangibles to foreign affiliates, services and intercompany transfer pricing matters, and can obtain advance pricing agreements in various jurisdictions.

It Does Not Matter The Stage of the Process - We Can Help

If intercompany pricing issues are raised by a taxing authority, we can defend clients at all stages of the administrative process. Our approach is to seek favorable settlements at the administrative level and to avoid litigation if possible. We can prepare detailed pricing reports, which require economic analyses and industry experts, as well as develop strategies to best present our client’s position and the case to the taxing authority (and, if necessary, in court) in collaboration with senior economists and pricing specialists.

Castro & Co. can minimize the expense and burden of your transfer pricing disputes with the IRS . We have reviewed scores of multi-million dollar transfer pricing cases and can counsel at every stage of the proceeding: IRS examination, Competent Authority, IRS Appeals, litigation, and the APA process.

Representation for Multinationals

We can assist U.S. multinationals as well as multinationals based in major North American and European countries, Japan, and tax haven jurisdictions in nearly any industry, including banking and financial products, pharmaceuticals, electronics, telecommunications, batteries, bearings, motorcycles, medical equipment, biotechnology, crude oil, oil field services, luxury items, industrial equipment, automotive components, fertilizer, and steel. The intercompany transfers have involved, either alone or in combination, the manufacture and/or distribution of tangible goods, the development, sale and/or licensing of intangibles, the incidental and/or regular provision of related-party services, and the making of loans.

Legal Assistance with Regulatory and Legislative Issues

We also help clients in legislative and regulatory matters relating to section 482. We can counsel industry trade associations on potential application of proposed regulations and legislation, including preparation of comments and testimony and meetings with government officials. We also have extensive knowledge of and experience with section 6662 transfer pricing penalty protection documentation, as well as with the preparation of cost-sharing agreements for international groups. Whether you are in Washington DC, Miami, Dallas or Orlando, where our offices are located or anywhere else in the world, let our firm represent you.

If your company is facing an IRS transfer pricing adjustment, or if you want to minimize the likelihood of a transfer pricing adjustment in the future, Castro & Co. can help in the following ways:

  • Evaluate your transfer pricing exposure and advise on minimizing future exposure.
  • Determine an appropriate transfer price or royalty rate for tangible and intangible property.
  • Determine ownership of intangibles and establish research and development cost-share arrangements.
  • Defend your transfer prices against adjustment and avoid double taxation through the Competent Authority process.
  • Defend “at cost” administrative services and interest-free advances.
  • Prepare Section 6662 transfer pricing reports.
  • Pursue legislative and regulatory solutions to transfer pricing issues.
  • Negotiate an advance pricing agreement with the IRS and foreign tax authorities.

For your first free consultation with Castro & Co. call (888) 595-5088!

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