Our international taxation lawyers, together with our transfer pricing consultants, assist multinational clients to develop, implement, document and defend their transfer pricing strategies. We also work with clients to obtain unilateral, bilateral or multilateral advance pricing agreements, or invoke the mutual agreement procedures of bilateral income tax treaties in the event of a U.S. or foreign initiated transfer pricing adjustment. We are particularly cognizant of the BEPS transfer pricing initiatives as well as the aggressive posture of various foreign countries in enforcing their transfer pricing laws.
Scope of Transfer Pricing Practice
Our transfer pricing practice encompasses:
- Determination of whether controlled parties or transactions exist
- Performing a functional analysis
- Planning in connection with the sale of goods; provision of service, sale, use or cost sharing of intangibles; use of tangible property, and loans
- Shared services arrangements
- Advance pricing agreements
- Mutual agreement procedures under bilateral income tax treaties
- Contemporaneous documentation
- Transfer pricing defense at administrative or judicial level
Accessibility And Collaboration
We work efficiently between time zones and continents with offices in Tampa, Florida; San Francisco, California; Washington, D.C and Zurich, Switzerland. Our attorneys are accessible and frequently collaborate to find the best solutions to meet the needs of our clients.