Transfer Pricing, Section 482
→ Ask us: about Transfer Pricing
Intercompany pricing can have significant effect on tax and many tax authorities are becoming increasingly innovative and commercial in their enquiries concerning transfer pricing. Intangible Businesses professionals have extensive transfer pricing experience across multiple jurisdictions for multi-national companies and government agencies.
Intangible Business recognizes that it is becoming risky to simply rely upon a file supporting transfer pricing strategies without considering the commercial substance behind it. By having a well structured and documented transfer pricing strategy in place or arranging an APA (Advanced Pricing Agreement) an unexpected tax bill can be avoided.
Intangible Business’ commercial focus incorporates a full understanding of supply chain economics and the value drivers of market segments to ascertain accurate and defensible transfer prices. Intangible Business applies its transfer pricing service in accordance with sections 482 and 6662 of the Internal Revenue Code though application of each of the preferred methods – CPM (Comparable Profits Method), CUT (Comparable Uncontrolled Transactions), Cost Plus, Residual Profit Split and Resale Price – in order to provide comprehensive and justifiable transfer pricing guidance, analysis and documentation.
When valuing intangible assets for purchase price allocations Intangible Business ensures that the valuation assumptions and the associated transfer pricing strategy are corroborative.
Our transfer pricing service is used for a variety of applications:
- Intercompany transfer pricing
- Purchase price allocation and associated transfer pricing strategy
- Audit support
- Expert witness testimony
If you have any questions, please call us on +1 312-794-7794 or send us an email.

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