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Transfer Pricing Rules

The need for objective transfer pricing opinions has evolved from multinational corporations actively managing their portfolios of IP and intangible assets by transferring or licensing them to foreign subsidiaries. These transferred or licensed assets are then used to generate taxable business income in different tax jurisdictions. As more companies consolidate and operate globally, the need for transfer pricing compliance has grown. Consequently, it is imperative that the valuation or transfer price conclusions be objective and supportable.

CONSOR offers extensive experience in the valuation of intellectual property and intangible assets for a wide variety of purposes including the transfer of assets between legal entities. CONSOR can assist you in generating significant benefits related to the reduction in worldwide federal income taxes paid while still complying with each taxing authority’s regulations and OECD guidelines. Ultimately, we will assist you in achieving your overall strategies by working with you to reduce the risk of costly audits and related penalties based on our knowledge and experience in this area.

We have helped numerous organizations develop a comprehensive and defensible strategy for transfer pricing issues related to trademarks, copyrights, patented technology and other intangible assets. Our services for these clients have taken the form of intellectual property valuation, establishment of appropriate royalty rates through either market-based comparables or proprietary calculation techniques, and licensing program implementation that incorporates the tax planning strategies most appropriate for the client’s needs.


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