IP Transfer Pricing Services
Even though your cross-border transactions may appear to be seamless, the Internal Revenue Service and other international tax authorities are watching closely (U.S. state tax authorities are also beginning to notice).
The tax authorities strive to ensure that the price set for IP that crosses international borders is set at an “arms-length” price.
A company’s transfer pricing policy can be affected by a variety of situations including: the transfer of IP ownership across international borders, inter-company licensing of IP across international borders, and products produced utilizing IP and subsequently sold to a related party across international borders.
All of these situations should be documented by a company’s transfer pricing program to minimize exposure.
If your company does not have a transfer pricing policy in place, you may have a significant risk of exposure to penalties and fees based on adjustments later mandated by a reviewing taxing authority; a penalty equal to 10 to 40 percent of the adjustment plus interest is not uncommon.
Request a Consultation for IP Transfer Pricing Services
Rogers DVS has experience in establishing the transfer pricing documentation to support your transfer pricing policies that should withstand the scrutiny of the taxing authorities. For intellectual asset consulting please contact us.
Other terms we may discuss with you related to IP transfer pricing & litigation:
transfer pricing dispute, transfer pricing guidelines, profit split method, controlled transaction, intangible assets