Clayway Certified Public Accountants has professional knowledge and can help your company manage risks through strategic transfer pricing schemes. Our team has a proven audit strategy and has successfully defended many companies facing huge tax adjustments and penalties. Klevey CPA has the practical knowledge to support your company’s global financial management strategy.
For companies engaged in cross-border business, transfer pricing is considered the most controversial tax issue. The intercompany prices charged for goods, services, royalties, and loans affect the income tax that companies pay to each country. As the IRS and many other tax authorities need to review transfer pricing as part of every tax audit, multinational companies are increasingly facing transfer pricing issues.
Transfer Pricing Service
- U.S. and international transfer pricing documentation
- Transfer pricing planning and cash flow improvement
- Transfer pricing audit defense
- Analysis of Transfer Pricing Benchmark Positioning
- Advance pricing agreement
- Transfer pricing due diligence
The transfer pricing team,
through the work of Alex Martin, the head of the transfer pricing department, Klevey Certified Public Accountants was named one of the world’s leading transfer pricing service companies by the International Tax Review. He has more than 20 years of experience in helping multinational companies meet transfer pricing requirements in more than 100 countries. Alex is supported by the company’s experienced tax consultants. He often consults accounting firms to seek US or global transfer pricing experience.
International Tax Services
Our international tax team is committed to minimizing the tax obligations of U.S. companies that expand overseas and foreign companies that set up operations in the United States. Throughout our history, we have provided customers with valuable financial, operational and tax planning strategies. In addition, our international alliance helps our clients obtain resources from all over the world.
- Foreign tax credit
- Permanent establishment
- The establishment of IC-DISC and taxation issues
- Repatriation of foreign proceeds
- Reorganization and physical structure
- Treaty analysis
One of the unique features of
Clayway Certified Public Accountants. One of the benefits of cooperating with Clayaway Certified Public Accountants is our in-depth understanding of entrepreneurial experience. Our company has established a good reputation in understanding the needs and challenges of enterprises in global market competition. We can work with your team to develop and implement a strategic transfer pricing plan as part of a global strategy.
Overview of transfer pricing : benchmark positioning analysis and transfer pricing documentation
|Benchmark positioning analysis||Transfer pricing documentation|
|purpose||Provide high-level texts to formulate transfer pricing strategies and target profit margins for subsidiaries||Prepare transfer pricing documents in accordance with US and global transfer pricing regulations to prove and protect transfer pricing results
Documents that are exempt from fines when making tax adjustments
|Applicable situation||Suitable for low-risk situations, such as start-up companies or companies with relatively low income
Establish a foundation or provide economic analysis guidance for the cross-border pricing of related transactions between companies
|Applicable to companies that have large transactions or higher risks with related companies
Certain countries/regions require the provision of transfer pricing documents when the threshold for related-party transactions is exceeded
|Delivered results||A high-level summary report on the business and industry, and determine the target range of the annual profit rate based on the financial performance of similar companies
The report usually has 10 to 15 pages
|Conduct in-depth economic analysis of related-party transactions between businesses, industries and companies to test whether the transaction complies with the principle of “fair trading”
Documents generally have 60 to 100 pages
|Defense level to respond to audits||Does not evaluate the “fair transaction” nature of related transactions between companies, and will not reduce the risk of punishment when the tax authority makes audit adjustments
Tax authorities do not need to agree to transfer pricing benchmark analysis methods
|First and foremost, it is the best opportunity to avoid transfer pricing audits.
If you submit prepared documents based on the tax declaration date, you can reduce the risk of penalties for transfer pricing adjustments, and must be updated every year to avoid fines. Tax authorities do not need to agree to transfer pricing documents.
Benchmark economic analysis requires limited fact-finding
|Preparation of transfer pricing documentation requires in-depth interviews and comprehensive factual and economic analysis
The cost depends on the amount of related transactions, the number of countries involved, and the complexity of related transactions between companies