Transfer Pricing
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NERA has developed one of the largest in-house teams of economists in the economic consulting world. Our global transfer pricing experts offer a full range of transfer pricing services, independent advice, and valuation support by world-class economists who operate in major locations around the globe and who team effectively to provide global solutions for multinational clients. Our direct, hands-on approach to transfer pricing enables us to develop more rigorous, higher quality products, and to collaborate more effectively with our clients. Because we are a firm of unbiased economic practitioners, many of the leading law firms from around the world have also engaged us to create valuable and sustainable solutions for their multinational corporate clients and as experts in litigation and arbitration. Our team of experts has substantial senior-level experience, and we work collaboratively with multinational clients and their legal and tax advisors to provide the highest level of practical hands-on advice and support, applying sophisticated economics-based techniques when necessary to tackle more difficult issues. Clients range from some of the largest and best known companies in the world to midsize companies, and they cover numerous iconic brands.
移転価格
NERAのエキスパートは、価格移転への直接的で実践的なアプローチを提供することで、より厳格で高品質な製品を開発し、より効果的にクライアントと協力することが可能になります。当社のエキスパートは、市場ベースの価格設定手法、ベンチマーク調査、厳格な価値評価手法を活用し、健全なビジネス戦略と十分に確立された経済原則に基づき会社間価格設定方針を設計かつ維持します。ビジネス、組織、経済、法律に関する専門知識が豊富であることから、当社の移転価格ソリューションはビジネス目標を満たし、防御的であり、国税当局が課す独立企業間要件を遵守していると言えます。
Advance Pricing Agreements
We have substantial global expertise structuring the economic framework of advance pricing agreements (APAs) and bilateral and multilateral agreements and assisting with negotiations between competent authorities (CAs) in the US, the UK, Canada, Japan, China, Australia, and the EU (including Germany, France, and Spain).
While key negotiation issues may vary among cases, NERA experts provide a broad range of support services including: developing negotiation strategy based on a clear understanding of tax authorities’ position and potential points of conflicts; providing economic analysis and evidence to reinforce support for the taxpayers’ position, and advising tax authorities about underlying economic theories and business practices; and developing alternative methodologies or preparing options to facilitate discussion and resolve "standoffs" in negotiation.
Cost Contribution/Sharing Arrangements
Recent court cases related to cost sharing arrangements and changes in the definition of intangibles following the Tax Cuts and Jobs Act of 2017 in the US have implications for existing and new cost sharing arrangements. We can assist in designing a cost contribution system that is in line with your business operations and complies with the new regulatory requirements with respect to the calculation of the buy-in amount for pre-existing intangibles and the scope and sharing of costs. By understanding your business, how value is derived, and where costs are incurred, we help structure arrangements that are aligned with the group’s operational model.
Tax Authorities and Regulators
Our independence and global reach are key assets when resolving complex tax and transfer pricing issues for regulators and tax authorities. We also partner with tax authorities to deliver training and create transfer pricing tools and materials that build local capacity.
Transfer Pricing Documentation
Our global regulatory work focuses on helping clients analyze and document their cross-border intercompany transactions in accordance with the tax regulations for the countries in which they operate. We have decades of experience working under OECD transfer pricing guidelines worldwide and under the auspices of the Internal Revenue Code in the US.
Valuation of Intangible Assets and Businesses
We assist in establishing arm’s length valuation of intellectual property—including technology intangibles, know-how, marketing and brand names, customer lists, and goodwill—for transfer pricing purposes. We also provide expert valuations of businesses and underlying assets for business restructuring purposes.
Controversy and Litigation Support
NERA’s controversy support capabilities build on our long and established reputation as reliable independent expert witnesses and our ability to apply sound, market-oriented, case-specific economic theory to the resolution of tax disputes. Our experience ranges from tax audit defense to litigation and international arbitration.
Financial Transaction Transfer Pricing
We conduct valuations in the context of restructurings, prepare defense files and documents, and support in disputes spanning all areas of financing arrangements, from treasury services, loans, and guarantees to cash pooling, hedging, and captive insurance, among others.
Transfer Pricing Design
We help design transfer pricing systems aligned with the overall value-creation process. Especially during mergers and acquisitions and business restructurings, it is fundamental that transfer pricing systems account for value creation across entities, ensuring a system that is well founded and sustainable over time.
Value Chain Analysis
Understanding value creation is vital for any business. Value chain analysis identifies the activities that enable a company to maintain a superior level of profits and competitive advantage in the long term. We use a unique four-step analytical process to help our clients understand how value is being created, how individual entities take part in the joint value-creation process, what their respective contributions are, and how each of them operates and carries responsibility for relevant categories of risk.