Transfer Pricing

Overview

Evaluating arm’s length prices for intercompany transfers, spin-offs and acquisitions, and tax planning, Edgeworth provides independent expert analyses, valuation, dispute resolution, and documentation to meet our clients’ domestic and international tax requirements.

Our experts apply rigorous economic, accounting, and statistical methods to determine arm’s length prices for goods, services, and intangible property, including spin-off business units, manufacturing and marketing services, and patents and trademarks. 

In each case, Edgeworth provides complete, rigorous documentation to meet the relevant transfer pricing or tax requirements, whether for domestic or international authorities. Edgeworth also works with clients, counsel, and other outside advisors to develop potential transactional structures that appropriately weigh relevant benefits and costs to achieve efficient value chain transformation and management. Our experts have transfer pricing experience in numerous industries, including pharmaceuticals, specialty chemicals, consulting services, and vehicles.

Documentation

Our experts quantify arm’s length prices and prepare documentation consistent with US and foreign tax guidelines for a variety of goods, services, and intangible assets, such as:

  • Patents and know-how
  • Tangible property
  • Manufacturing or assembly services and related functions
  • US and local entity valuation

Tax Planning

Edgeworth experts, working with tax counsel and advisors, assist clients with a variety of tax planning issues, including:

  • Determining buy-out payments for technologies developed under cost-sharing or other development agreements
  • Analyzing the tax consequences of licensing or selling intellectual property to affiliates

Dispute Resolution

Edgeworth provides a full range of audit and dispute support for clients dealing with domestic and international tax authorities, including:

  • Preparing supplemental information or analyses to assist in discussions and negotiations with tax authorities
  • Providing critical evaluations of adjustments proposed by tax authorities

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Related Capabilities

In this Bloomberg BNA article, Dr. George Korenko from Edgeworth Economics and Karl L. Kellar and Lori Hellkamp from Jones Day analyze explore “the intended and unintended effects [the proposal] could have on the economy . . . and tax policy.”

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