Identify risks and uncover opportunities in your global tax strategy
Transfer pricing refers to the prices set for transactions between related entities within a company. These transactions can include the transfer of goods, services, intellectual property, or financing arrangements.
Are you ready to turn transfer pricing complexity into clarity?
BACKGROUND
A US company, the parent of a $50M global enterprise, had expatriates working in its UK subsidiary, generating $15M in UK revenue.
CHALLENGE
The Transfer Pricing Diagnostic revealed a significant risk due to unchecked profits in the UK subsidiary without transfer pricing support. However, the opportunity was even greater than the risk.
SOLUTION
By appropriately aligning profit in the UK subsidiary with transfer pricing principles, the company:
Key Notes
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IRS PenaltiesPotential Risk: 40% of the disputed difference in immediate tax penalties Option 1: Full penalty protection: Create and document complaint transfer pricing policies Option 2: Penalty mitigation: Outline transfer pricing policies in truncated support |
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Reduced Income on the Sale of Your BusinessPotential Risk: Lower offer price for your business because transfer pricing is not established Option 1: Develop and document transfer pricing to prepare for deal diligence Option 2: Equip deal principles to address transfer pricing concerns through correspondence |
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Reduced Leadership MoralePotential Risk: Employee turnover Option 1: Align success metrics to value creation with documented processes Option 2: Recognize and communicate value creation across the organization through correspondence |
Key Notes
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Improved Cash FlowPotential Opportunity: Up to 10% or more of taxable income Option 1: Analyze business with transfer pricing lens, calculate and execute adjustments, record strategy with full documentation Option 2: Estimate and execute transfer pricing adjustment (higher risk without documentation support) |
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Improved Effective Tax RatePotential Opportunity: 20% lower (or more) global effective tax rates Option 1: Consider global entity strategy and tax advantages and formally document transfer pricing support Option 2: Create truncated transfer pricing policies reflecting business strategy |
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Effective Policies for Global ExpansionPotential Opportunity: Aligning policies with facts to lower both taxable income and effective tax rates Option 1: Establish and document comprehensive transfer pricing policies for global expansion Option 2: Apply regular macro-level transfer pricing adjustments based on truncated analysis |
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