We assist multinational companies with transfer pricing consulting services to reduce risk inherent in their transfer pricing positions, comply with country documentation requirements to explain the purpose, substance and reasoning behind each transfer price, and resolve and avoid disputes with tax authorities. We do this in a bespoke manner specific to each client’s business in the following ways:
Planning, amending, or restructuring international related-party transactions – setting new policy, revising existing policy and transferring knowledge to management so policies are understood, practical, aligned with business operations, and are manageable in-house.
Assisting companies to manage and resolve transfer pricing risk that arises in M&A transactions and as part of tax provision reviews.
Managing and overseeing a transfer pricing audit or examination (often with attorneys and accountants), and using economic analysis and controversy strategy to advocate for a reasoned, arm’s length outcome when disputes arise with a tax authority
Complying with Canadian and U.S. annual transfer pricing documentation requirements, and coordinating our activities with accounting firms that prepare corporate tax returns and international transaction reporting forms
Our transfer pricing consulting services also include resolving a double tax issue using a Mutual Agreement Procedure.
Achieving certainty using a bilateral Advance Pricing Arrangement between tax authorities
