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In today's global business landscape, transfer pricing is more than just a compliance requirement. It's a strategic imperative.

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?

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By understanding and enhancing your transfer pricing strategy, you can:

  • Help ensure compliance and avoid costly penalties
  • Improve your global tax efficiency
  • Enhance cash flow management
  • Increase your readiness for potential business transactions

Why it matters to you:

  • If you have overseas operations, the IRS must analyze your intercompany pricing
  • Transfer pricing impacts your tax liability, cash flow, and business value
  • With the right strategy, it can be transformed from a risk into an advantage

Our Transfer Pricing Diagnostic:

  • Uncovers risks and opportunities
  • Requires minimal investment
  • Provides actionable insights

The Process

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45-minute conversation with key stakeholders
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Simple spreadsheet populated from your ERP or financial system
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$2,000 diagnostic fee (applied to project costs if pursued)
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You'll then receive a ranked list of your transfer pricing risks and opportunities and practical options to address risks and capitalize on opportunities

CASE STUDY

REAL RESULTS

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:

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Results the company saw

Improved cashflow by

$250K

Realized annual tax savings of over

$40K

Gained IRS penalty protection

Received ongoing tax savings well beyond the cost of documentation

Detailed Insights

Examples -- Largest Risks Identified

Our diagnostic report identifies critical transfer pricing exposures that could impact your business. While each analysis is tailored to your organization's specific circumstances, below are some examples of potential risks we commonly uncover and how to address them.

Key Notes

  • Some solutions may address multiple risks simultaneously
  • Option 1 typically provides comprehensive risk management
  • Option 2 offers a pragmatic, potentially lower-cost approach
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IRS Penalties

Potential 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 Business

Potential 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 Morale

Potential 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

 

Examples -- Largest Opportunities Uncovered

Our diagnostic report also unlocks hidden value within your transfer pricing structure. Again, while each analysis is tailored to your business's unique characteristics, here are some examples of the opportunities we typically uncover and how you can capitalize on them.

Key Notes

  • Some solutions may address multiple opportunities simultaneously
  • Option 1 typically provides comprehensive opportunity management
  • Option 2 offers a pragmatic, potentially lower-cost approach
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Improved Cash Flow

Potential 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 Rate

Potential 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 Expansion

Potential 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

 

 

Don't leave money on the table

Let our experienced transfer pricing specialists help you enhance your global tax strategy.

 

Request a consultation