Transfer Pricing

Our tax lawyers regularly work with our clients’ economists and valuation advisors to comply with the intricate U.S. transfer pricing rules. We counsel companies on the range of available methods to determine a transfer price and the documentation that must be collected. We have particular experience on issues affecting the development, transfer and exploitation of intangibles, including IP rights. We help our clients negotiate advanced pricing and related agreements and regularly assist in implementing intercompany cost sharing arrangements for the development of intangibles and shared services arrangements with respect to covered services. We participate in competent authorities’ proceedings, and we defend transfer pricing issues before the IRS on examination and before Appeals.