Business today is global, with increasing and varied cross-border intercompany transactions giving rise to a multitude of international tax valuation issues. Among these issues is transfer pricing, the application of valuation principles in the context of international tax rules in the determination (and documentation) of an arm’s length result.
More than 70 countries now require companies to substantiate and document that intercompany transactions are on an arm’s length basis for income tax compliance purposes. The practices and principles applied in transfer pricing and financial reporting are converging, particularly in areas such as ASC 740, Income Taxes (FIN 48), and intangibles related to international business restructuring transactions. Tax authorities throughout the world have increased their resources to intensify their scrutiny and enforcement of transfer pricing.
But transfer pricing is more than just compliance. Companies seeking to improve their strategic position and shareholder value through business combinations, supply chain and cost rationalizations or other organizational restructurings can effectively tailor their transfer pricing position, through proper planning and structuring, to mitigate tax exposure and optimize their global effective tax rate.
Wherever and whatever your transfer pricing needs, American Appraisal has a global team ready to serve you. With 900 valuation professionals in 24 countries, American Appraisal has the experience, reach and resources to address and deliver transfer pricing solutions anywhere, anytime. Our solutions provide local insight and are coordinated globally to ensure consistent standards and best practices.