Transfer pricing: Leading documentation practices for multinationals

August 2013


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.

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

Nick Raby
Tel: +1 (713) 356 4001

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

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