Transfer Pricing Services

Effective global transfer pricing planning is key to managing the global tax rate, to maintaining optimal supply chains and intangible property (IP) structures, and to establishing defensible transfer pricing policies and governance. Weaver’s transfer pricing advisory services identify opportunities, model scenarios and impacts, benchmark arm’s length outcomes — and appropriately value functions, assets and risks. Weaver’s team can help with complex financial transactions and intangible properties that are difficult to value. Our well-developed transfer pricing policies support a wide range of organizational priorities.

Weaver’s team increases certainty and mitigates risk arising from the complexities of uncertain tax positions, financial reporting reserves, double taxation, controversy and penalties — and provides globally efficient cash deployment and repatriation. While transfer pricing typically focuses on corporate income taxes, transfer pricing positions and potential adjustments can have significant secondary impacts on customs duties, state or provincial income taxes, value added taxes (VAT), goods and services tax (GST)/harmonized sales tax (HST), excise taxes, sales and use taxes and more. To avoid unnecessary impacts to deal pricing, holdbacks or delays in a deal closing, our professionals ensure you have appropriate intercompany agreements, transfer pricing methodologies, and transfer pricing documentation in preparation for due diligence.

For compliance with local tax regulations, countries worldwide have greatly increased the focus and reach of transfer pricing documentation requirements and international dealings reporting. Weaver can assist businesses with navigating U.S. and foreign transfer pricing regulations and with preparing documentation that follows specific local country compliance requirements.

Our team is well-versed in master files, local files, international dealing schedules, country-by-country reporting (CBCR) and notifications, controlled foreign corporation (CFC) reporting, and other localized regimes that can create significant burdens. We’ll evaluate compliance requirements and corresponding penalty provisions and maintain compliant documentation to support transfer pricing positions taken on tax returns. Weaver’s professionals understand various penalty regimes that affect transfer pricing compliance in jurisdictions across the world. We’ll ensure a timely preparation of transfer pricing documentation and reporting that offers the most effective means of mitigating transfer pricing controversy and penalty risk.

Tax authorities globally are focused on transfer pricing as a high-risk area for tax base erosion, which drives a significant increase in enforcement resources, transfer pricing audits, transfer pricing controversy, and adjustments to local tax due. Weaver’s professionals can help prevent controversy and navigate the complexities of transfer pricing audits, penalties and relief options.

Double taxation caused by transfer pricing adjustments represent the most significant and fundamental risk in transfer pricing. As transfer pricing audits and controversy are on the rise globally, Weaver helps your business avoid substantial time, effort and fees incurred in mitigating double taxation. While relief may be available with treaty partners, the cost-benefit analysis of pursuing available avenues for relief can be prohibitive in terms of fees, length of process and uncertainty of outcomes.