Transfer Pricing

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Multinational enterprises are facing increased scrutiny from tax authorities in relation to transfer pricing. Failure to comply with documentation requirements could result in significant penalties.

This is why you need an experienced resource to assist your organization in developing transfer-pricing policies that are defensible and congruent with your company's overall tax planning. 

What is transfer pricing? The price that is charged for intercompany transactions involving products, services, or intangible properties in order to calculate each company's profit and loss separately. These transactions between related parties are subject to transfer pricing standards enforced by the IRS and taxing authorities worldwide. They may also be used to determine state income tax. The U.S. arm’s-length transfer pricing standard and penalty provisions are detailed in IRS Code Sections 482 and 6662, and applicable case law.

A Distinct Approach to Transfer Pricing

Our transfer-pricing resources are integrated with international and state and local tax plans, including the development of cross-border tax strategies. We can help your company develop innovative approaches to complex intercompany transactions that may add value to your business operations from both a tax-management and implementation perspective.

Our transfer-pricing services include:

Planning and Analysis

  • Comparables analysis
  • Functional analysis
  • Intangible-property valuations
  • Cost-sharing arrangements and buy-in payments

Compliance

  • Documentation compilation
  • Intercompany policy and implementation guidelines
  • Intercompany agreements

Audit Support

  • Tax-authority response and negotiations
  • Dispute resolutions

Learn More

To learn more about Blackman Kallick's Transfer Pricing practice, please contact: 


This publication is part of Blackman Kallick’s marketing of professional services, and is not written tax advice directed at the specific facts and circumstances of any person and/or entity. Contents of this publication are of a general nature, and you should not act on this information without obtaining professional advice from your business advisor that is appropriately tailored to your individual needs and circumstances. This written advice is not intended or written to be used, and cannot be used by any taxpayer, for the purpose of avoiding penalties that may be imposed under the Internal Revenue Code.