Intercompany Transfer Pricing, including Intellectual Property - IRC§ 482

As businesses expand globally, international transfers of products and services between affiliates have grown rapidly. Every United States firm, with foreign operations - regardless of size - is required to implement and document their transfer pricing in compliance with IRC §482. In addition, the Organization for Economic Cooperation and Development's Committee on Fiscal Affairs has set guidelines that are very similar to the United States' code.

However, regional differences in transfer pricing policy are important and include formatting, record keeping, and methodology preferences, coupled with the need for a solid understanding of the general environment. This generates an escalating call for multinational firms to focus on their transfer pricing policies and to seek innovative solutions to them. The corporate taxpayer may best support his position by having the economic analysis and transfer pricing documentation prepared by an independent expert. HSSK specializes in the type of independent, economic analysis required to conduct and substantiate a transfer pricing study.