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
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
- Determine ownership of intangibles and establish research and development
- 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.
first free consultation with Castro & Co. call (888) 595-5088!