Transfer Pricing

Lieberman has the industry experience, technical ability, and sound judgment to deliver results for our clients.

The majority of countries have transfer pricing regulation in their domestic tax legislation. The main goal of transfer pricing is to allocate the profits between the parent company and its subsidiaries. Lieberman solves complex transfer pricing issues for multi-national corporations. Our team provides proven and practical solutions for planning, implementation, supply chain structuring, and compliance.

Every transaction between controlled taxpayers must be measured as if the parties were unrelated and dealing at arm’s-length. Transfer pricing guidelines are becoming stricter and more complex. Today, businesses operating in multiple country jurisdictions are being subjected to tax burdens by both the U.S. and international tax authorities.

Our solutions include the following:

Strategic Planning

Strategic planning creates an operational framework, supported by robust economic analysis, to assist organizations in proactively addressing the transfer pricing impact of increased scrutiny in a globalized economy. By integrating managerial and tax objectives in transfer pricing, we assist organizations in legal entity restructuring, valuation, and IP planning that improve tax efficiency and mitigate regulatory risk.

Implementation

Our team conducts extensive analysis of intercompany transactions to deliver a harmonized, end-to-end approach to transfer pricing reporting and compliance. We evaluate an organization’s controlled and uncontrolled transactions to apply an appropriate pricing method based on the arm’s-length principle. Through close collaboration with management, we develop a transfer pricing strategy that leads to tax savings and a defensible transfer pricing policy.

Intellectual Property Valuation

Knowing the value of your organization’s IP is crucial for setting the transfer price for an intercompany licensing transaction. We analyze the complex features of IP assets to determine the appropriate valuation method to establish arm’s-length transactions.

Multiple entities within an organization may have been involved in the creation of an intangible’s value. The OECD has established guidelines to help both organizations and tax authorities assess the accurate allocation of profits and costs to those entities that contributed to the value of the IP asset. Our team conducts a functional and risk analysis to identify which related entities contribute to the development, enhancement, maintenance, protection, and exploitation of IP. Our analysis ensures that your organization is complying with OECD guidance by accurately describing the controlled transaction so that arm’s-length transfer pricing can be established.

Compliance and Documentation

The documentation requirements of Treasury Regulation 1.6662-6(d) compel that a general description of each party to a controlled transaction under review be provided. With input from both operations and tax management, we construct a comprehensive study that outlines the transfer pricing strategy covering all affiliates that are involved in global transactions. Our experienced team has also successfully provided consulting services for clients in need of transfer pricing comparable benchmarking studies for tax planning purposes.

Dispute Resolution

Lieberman provides independent expert reports to support taxpayers and their legal counsel. We review and analyze the positions taken by tax authorities and other regulatory organizations to resolve litigation cases in a favorable manner for our clients.