Transfer pricing is been a one of the hottest issues in recent years. Internal Revenue Service is looking into multinational companies conducting any kind of inter-company transactions. Also call controlled transactions. Transaction between two related parties. This can also be two unrelated taxpayers’ acting in concert with a common goal or purpose as it allows taxpayer to allocate the income into a lower tax jurisdiction. Recently, this issue is not only limited to multinational companies but also applies to companies that have presence in multi states of the USA. Our services include but are not limited to issues related to:
- Allocation of income and deductions between taxpayers.
- Arm’s length transactions requirements.
- Related-party services regulations
- Tangible or Intangible property related transaction. heavily tested
- Comparable profits method
- Profit split method
- Cost sharing method
- Best Methods Rule