Our Services

Transfer Pricing

Peters Advisors has the experience and expertise to work with your team to provide solutions to your transfer pricing issues.

Transfer Pricing Compliance – Global compliance with transfer pricing rules can be bewildering and overwhelming. We can help you develop an approach to effectively and efficiently comply with the myriad of transfer pricing rules and documentation requirements.

Use our assistance to help you evaluate what needs to be documented and how extensively. We can also share best practices regarding how best to leverage your efforts across your system.

Transfer Pricing Documentation

  • Section 6662 U.S. Transfer Pricing Documentation – we can work with you to produce the requisite documentation to support your tax return, including performing the entire economic analysis and report-writing.
  • Global Transfer Pricing Documentation – we can help you develop a “Masterfile” approach and develop a sensible documentation approach in all your operating jurisdictions.

FIN 48 support – You need to determine and properly support tax provision reserves related to transfer pricing. We will work with your team to develop appropriate framework and analysis to support your reserve for unrecognized tax benefits (UTB’s).

Transfer Pricing Planning – Good transfer pricing all starts at the initial planning stage. We can assist you in determining an effective and supportable philosophy to price all your intercompany transactions, and then help you drive the implementation of your vision.

  • Intellectual Property – Managing and valuing your IP is the most challenging and controversial aspect of transfer pricing. We will work with you to get it right. We have specific expertise in cost sharing agreements, license agreements, and sales/transfers of all types of intellectual property.
  • Tangible Goods – Managing the pricing of the flow of tangible goods along your supply chain is a challenge for income tax, customs, and (often) operational performance management purposes. We can work with you to balance all of these sometimes conflicting priorities.
  • Services – Effectively pricing services can be a challenge: was value added, and how much? Our team has extensive experience with the proper structure and treatment of service arrangements, including contract manufacturing, commissionaire/commission agents, and contract service agreements.
  • Stewardship – Properly defining what constitutes stewardship continues to be a challenging and controversial area of transfer pricing. Our team has extensive experience in this area and can help you develop a sustainable approach to this issue.
  • Intercompany Financing – Intercompany financing is becoming a focus area of tax inspectors. We can help you structure and properly support your financing arrangements (loans, guarantees, factoring, insurance) so that they are properly characterized.

Transfer Pricing Disputes – the ultimate test of your transfer planning and compliance efforts is how they fair under the scrutiny of the tax authorities. Peters Advisors can help you and your legal advisors throughout the dispute process.

  • APA’s – APA’s are the alternative to transfer pricing disputes: agree the pricing with the authorities in advance of the transactions. Our independent team can work with you and the governmental authorities to achieve methodological agreement on your transactions.
  • Audit Defense – the transfer pricing audit is often an educational process for the fiscal authority’s audit team. We can work with you to properly manage this process, and provide supplemental analysis and documentation as necessary to support your positions.
  • Competent Authority Proceedings – transfer pricing disputes often result in competent authority proceedings between the impacted parties. We have experience assisting clients with working with the competent authorities to achieve an acceptable outcome.
  • Appeals and Litigation – Transfer Pricing disputes often end up in the Appelate process, and sometimes can’t be resolved without litigation. We have extensive experience in working with clients and their legal advisors to provide the analytical support to achieve acceptable outcomes in these venues.