Transfer pricing is one of the most significant issues facing domestic and multi-national corporations conducting cross-state or international transactions. Regulations vary by jurisdiction and transaction type; thus, tax authorities worldwide are keen on ensuring their fair share of tax revenue. The risk of being challenged on transfer pricing practices is no longer a dream but a present reality.

While the penalties can be steep for organizations that fail to satisfy the required transfer pricing standards, understanding how critical optimizing transfer pricing is to your organization may create an opportunity to avoid these penalties. At Jeas Corp, we believe transfer pricing can be a tool to help manage your tax exposure, maximize business opportunities and, where appropriate, identify your optimal tax structure.

If your organization is participating in any cross-border transactions, you should have a transfer pricing strategy in place to eliminate risk of penalty. Jeas will work with you to develop a customized solution for your organization to ensure a successful future for your organization. We invest deeply in understanding our clients, and act as an independent and objective advisor.

Transfer pricing is a pricing arrangement for a transaction between related legal entities within a multinational enterprise. Intercompany asset transfers may include the transfer of tangible goods, services, intangibles and loans.

Tax authorities around the world have become more assertive to enforcing transfer pricing regulations and initiating harsher penalties and new documentation requirements. In the United States, non-compliance may result in a penalty ranging from 20% to 40% of the underpayment of tax. Globally, countries have initiated country-by-country reporting that may be shared amongst tax authorities.

Change is a constant for multinational companies. Global expansion, mergers and acquisitions, changing tax laws and regulatory requirements, and the global effort to fight base erosion and profit shifting all place stresses on a company’s global structure. Symptoms of a less than ideal structure include an increasing effective tax rate, difficulty accessing cash, cumbersome and disjointed accounting practices, and confusion and uncertainty when making business decisions. Our international tax structuring professionals are positioned to help you. We take the time to understand your business and collaborate with you to design and implement appropriate structural changes.

Our Approach:

Our four-steps approach is designed to provide you with a low-cost estimate of potential costs and benefits before you commit resources to a structuring project, and to maximize your return on investment after you’ve made an informed decision to move forward. Our process includes the following steps:

• Feasibility and modeling: Assess your unique business challenges and opportunities, generate preliminary design ideas, and model potential costs and benefits.
• Design: Develop a global structure to address your objectives.
• Implementation: Work with you and your advisors to implement the structure.
• Maintenance and reporting: Provide whatever level of support you need to maintain and report the structure. Maintenance services include ensuring that recommended policies and practices are being followed, intercompany agreements and transfer pricing are kept current, and other related tasks.

Assessing transfer pricing challenges from all perspectives

Our business advisors understand the necessary care and precision required for cases that tax authorities and/or courtsmay reviewed. Our experts can develop a tax planning strategy that can help minimize your exposure to transfer pricing adjustments and tax penalties.

Jeas Corp offers transfer pricing services to help manage and grow your business. Our services include:

• US and non-U.S. transfer pricing documentation studies
• Transfer pricing planning and strategy
• Advance Pricing Agreements
• Business Valuation for intercompany asset transfers
• Country-by-Country reporting
• Transfer pricing documentation
• Cost allocation studies
• Supply chain structuring
• Cost sharing arrangements
• Implementation services
• Global Structuring
• Design, implementation and reporting for multinational businesses
• Cash mobility and repatriation planning
• Holding company structures
• Intellectual property planning
• Global supply chain management
• Entity rationalization
• Transfer pricing planning and compliance
• Value-added tax planning and compliance
• International assignment services planning and compliance

Transfer pricing:

Many foreign countries seek additional sources of revenue and have turned their attention to more aggressive auditing of transfer pricing. The IRS has broadened its focus on multinational companies, meaning the number of transfer pricing audits is likely to increase in the coming years. The risk for noncompliance with proper transfer price documentation has never been higher.

We have a 10-step process to analyze, evaluate and document the wayyour company determines pricing for the products, services and intangibles (i.e. trademarks, patents, copyrights) transferred between related companies. Improper documentation can result in additional taxes, interest and penalties.

We work with you to develop and implement proper transfer pricing strategies to minimize your risk and tax exposure. Read more about our Transfer pricing services:

• Integrated planning for global growth
• Transfer pricing e-book
• Transfer Pricing Documentation
• Advance Pricing Agreements
• Cost Allocation Study
• Supply Chain Structuring
• Cost Sharing Arrangements