Transfer Pricing

At L&V, we understand the complexity of transfer pricing regulations. From an inbound and outbound service perspective we analyze both sides of the transaction and test for applicability under the arms-length transactional rules. We review, analyze, execute and support:

• Transfer pricing studies
• Tax treaty considerations
• Contemporaneous documentation requirements including benchmarking, comparables and functional economic analysis
• OECD considerations
• Business model strategies
• Affiliated legal agreements to fit your business models
• Parent company master service agreements
• Operational processes of transfer pricing
• Measurement of effectiveness; E&P analysis
• Intellectual property transfers, value and protection
• Audit management positions and responses
• Components outside of transfer pricing scrutiny
• Tax planning strategies