Transfer Pricing
Focused on Maximizing Growth and Building Value
Citrin Cooperman has been instrumental in assisting multinational companies maximize growth and build value within their global organization, particularly in the area of transfer pricing. To that end, our multi-phased approach to transfer pricing starts by conducting business interviews and discussions with a company's key personnel in order to gain an understanding of the business model and the issues critical to their success. We then identify the best transfer pricing methodology and determine the appropriate arm’s-length pricing structure through financial and economic analyses to help them achieve their business and tax objectives.
How Citrin Cooperman Can Help
At Citrin Cooperman we are working with multinational companies who are experiencing significant growth globally to develop tax-efficient strategies that conceptualize, analyze, and institute appropriate transfer pricing principles from the outset. Our transfer pricing services optimize the cross-border transfer pricing of goods, services, intellectual property, and financial instruments between related companies.
- Contemporaneous documentation studies (ranging from high-level analysis to complete reports) satisfying the local jurisdiction’s tax regulations including CbC reporting, master file, and local file;
- Litigation support;
- Global restructuring for tax optimization and/or operational efficiency;
- Structuring for capitalization and repatriation strategies;
- IP migration and planning;
- Implementation;
- Advance Pricing Agreements;
- Review of transfer pricing exposure under ASC 740 (Fin 48); and
- Due diligence.