Mitigating risk and optimizing tax efficiency.
Transfer pricing is widely acknowledged as the most important tax issue facing multinational businesses. Although transfer pricing raises significant compliance issues, it can provide excellent opportunities for tax optimization. Appropriate transfer pricing policies are of fundamental importance to group tax and risk management strategies.
Mazars in the US's Transfer Pricing Practice has assisted clients in a range of industries to achieve BEPS compliance, and prepared analyses and documentation under local laws and regulations worldwide.
As part of Mazars Group, we are able to leverage the deep resources and experience of our global firm, consisting of 47,000 employees and partners in over 95 countries and territories. Wherever your business takes you, we will be by your side.
- Documentation under US IRC § 482 and US IRC § 6662
- Documentation under OECD and local regulatory guidelines
- BEPS Master and local file preparation
- Country-by-Country Reporting (CbCR) compliance
- Documentation for state and local tax purposes
Consulting and Planning
- Price, profitability, and rate benchmarking
- Transfer pricing policy development and implementation
- Business structure, value chain, and operational performance optimization
Controversy Defense and Dispute Resolution
- Preparation of responses to information document requests
- Defense of practices and documentation under audit
- Assistance resolving disputes under US and OECD mutual agreement procedures
Advance pricing agreements
- Bilateral and multilateral APA negotiation assistance and analysis
- APA compliance documentation
Audit support services
- Analysis and documentation of ASC 740-10 Transfer-Pricing Tax Positions
- Review of documentation, policies, and processes
- Risk exposure assessment