The No. 1 international tax concern cited by global companies is transfer pricing; specifically, the potential for double taxation. It’s not an unfounded worry. As a multinational enterprise involved in related-party transactions, your company confronts the threat of double taxation and severe penalties for noncompliance with domestic regimes. In many jurisdictions you are required to document your transfer pricing method and must be prepared to defend your choice. As transfer pricing rules and regulations continue to grow more complex and burdensome, now is the time to focus on how you can most efficiently—and effectively—navigate the complex and confusing rules of a global enforcement environment.

Through their considerable experience, our transfer pricing professionals are uniquely in touch with the complexities of audit defense, tax treaty issues and international tax dispute resolution. Our combined knowledge of the issues, processes and competent authority functions around the world is unrivaled. We specialize in resolving all types of issues faced by multinational enterprises operating both within and outside the treaty network, and we have high credibility with government officials and current competent authorities around the world.

Our International Competent Authority (ICAT) services span three key areas:

• Strategic planning. As you pursue global expansion or business transformation, you must anticipate both the obstacles to and the opportunities of your plan. We help you plan and prepare so that you can enter new markets with confidence and accelerate problem resolution more effectively.
• Compliance. We help you ensure that your enterprise is in compliance with double taxation treaties around the world, so that you avoid costly penalties and noncompliance headaches associated with transfer pricing audits.
• Dispute resolution. We can help you manage the appeal process when issues arise, including negotiation with relevant competent authorities and assistance with litigation, if necessary.

We can also help you obtain prospective tax relief, including an Advance Pricing Agreement.