Transfer pricing: Leading documentation practices for multinationals

August 2013

Overview

The US requires contemporaneous documentation as described in Treas. Reg. section 1.6662-6(d)(2)(iii) – to be in place at the time the return is filed in order to obtain penalty protection.

Transfer pricing adjustments continue to be a key focus of the Internal Revenue Service (IRS) and foreign tax authorities as they can result in large tax deficiencies. A proactive approach to analyzing and documenting inter­company transactions on an enter­prise-wide basis is vital to managing transfer pricing audit risk for multina­tional companies. Leading practices dictate that transfer pricing policies and procedures be documented in a cogent, concise, complete, coordinated and contemporaneous manner in order to achieve more favorable outcomes in a controversy situation.

Contact us

Dale W. Bond
Partner
Tel: +1 (713) 356 4156
Email

Nicolas L. Raby
Principal
Tel: +1 (713) 356 4001
Email

Elizabeth A. Sweigart
Director
Tel: +1 (713) 356 4344
Email

Follow us