Practice Areas

Transfer Pricing

The continuous changes in the legislation of many countries have increased the importance of adopting and documenting defensible transfer pricing policies.

The U.S. have enacted the most sophisticated body of transfer pricing regulations worldwide and the U.S. tax authorities have sought stricter enforcement with higher penalties, detailed documentation requirements, bilateral exchange of information, increased specialization and resources devoted to tax exams.

Our specialists help companies reduce the likelihood of potential adjustments by tax authorities. In order to achieve these objectives, we help clients to allocate functions, risks, and tangible and intangible assets among affiliate entities.

Unilateral and bilateral Advance Pricing Agreements with the tax authorities can provide valid alternative dispute resolution forums and the opportunity to resolve transfer pricing issues for past as well as future years in a cooperative context. Funaro & Co. has successfully assisted numerous clients in connection with transfer pricing examinations and the negotiation of Advance Pricing Agreements.

Download Transfer Pricing Brochure