Tax Controversies
Fact finding, detail analyses, execution, and delivery.
As the world becomes flatter and cross-border trade between countries grows, taxing authorities around the world are becoming more aggressive in auditing of intercompany pricing. Recently identified by the IRS commissioner before Congress as an area with "significant compliance problems," companies must be able to defend the economic and financial aspects of transactions involving a domestic entity and its foreign affiliate with a rigorous command of facts at a level of detail above what typical accounting systems normally capture. The overwhelming amount of data to be sorted, compiled, and analyzed can be daunting. That's where Huron professionals step in.
Huron offers a full range of assistance with transfer pricing, in both planning and controversy settings. Whether you are just starting to plan for international expansion or are looking to optimize existing global operations Huron provides accounting, valuation, and economic analyses that are suited to the challenges you face. Increasingly complex and demanding tax regulations require your company to find reliable strategies for doing business in worldwide markets.
Huron's experts have a deep understanding of transfer pricing disputes, from fact finding and detail analysis to execution and delivery. Our experts have prepared numerous reports and testified before courts on intercompany pricing issues to assist in the resolution of matters on behalf of some of the most recognized companies in the world.
Transfer pricing assignments are very fact intensive, often requiring significant, in-depth knowledge of a company's financial and cost accounting systems and data structures along with the internal information technology systems that drive them. Huron helps clients and their attorneys uncover all relevant financial information in a transfer pricing dispute by reviewing the client's business records, both hard copy and electronic, culling massive amounts of data and organizing that data to provide powerful, yet manageable information essential to defining the tenability of the client's position. After all, any economic or valuation analysis is only as good as the foundational facts upon which it has been built.
In considering the disparity between the standpoints of a tax authority and a company, Huron works with counsel to develop a strategy to highlight the strengths and address the weaknesses of the company's position. Further analyses of key issues surrounding the transaction ensure superior understanding of the facts, allowing for a potent and robust stance. Drawing on our extensive transfer pricing dispute experience and command of company financial data, Huron helps clients determine the most effective presentation of facts to provide compelling, concise, and straightforward argument, in settlement negotiations or a trial setting.
The transfer pricing group at Huron can support your multinational company as you document and defend your intercompany pricing practices for the sale of products, provision of services, and cross-border transfers of intellectual property. Huron's professionals have extensive experience assisting clients in determining royalty rates, establishing cost-sharing arrangements, and determining fair market value for sales of intangibles. Our expertise encompasses a range of industries, including pharmaceuticals, high technology, transportation, food and beverage, manufacturing, electronics, and apparel.
Our professionals have performed analyses in the following areas:
- Transfer pricing planning
- Audit/APA/Competent Authority support
- Documentation studies
- Litigation consulting