Achieving Success with Cross-Border Transactions
With a growing number of companies doing business overseas, cross-border transactions between related parties have increased in frequency and complexity. Tax authorities around the globe, recognizing the potential for income shifting to lower-taxing jurisdictions, have intensified their efforts to develop and scrutinize compliance with transfer pricing regulations governing intercompany transactions.
Transfer Pricing Service Offerings
Rehmann’s transfer pricing team can help your company successfully manage these developments with the following services:
- Contemporaneous documentation to ensure compliance with U.S. (IRC Sections 482 and 6662) and foreign transfer pricing regulations in order to avoid transfer pricing penalties.
- Tax planning regarding outbound and inbound transfers of intellectual property and intangible assets, including valuation analyses.
- FIN48 analyses and reviews to support tax reserves attributable to transfer pricing Uncertain Tax Positions (UTPs).
- Preparation of cost-sharing arrangements and advance pricing agreements with intercompany affiliates in foreign jurisdictions.
In the U.S., transfer pricing penalties range from 20 percent to 40 percent of the tax underpayment. Abroad, regulations and penalties vary by country; your company may be required to file contemporaneous documentation for intercompany affiliates located in foreign jurisdictions. Our support spans the globe to ensure compliance and help you avoid such penalties.