The experts at True Partners Consulting relish the challenge of guiding clients through the complex process of transfer pricing. Our world-class tax and economic advice is accessible across the globe—either through our U.S. and UK-based practices, or through our affiliated firms in the True Partners Consulting International Network.
In the U.S., we help clients in complying with the arm’s-length standard under Section 482 of the Internal Revenue Code. This requires transactions with foreign related parties to be priced consistently with transactions between unrelated parties. The burden of proof is placed squarely on the taxpayer; IRC Section 6662 requires that compliance be documented contemporaneously with tax returns.
Outside the U.S., our client advocacy is based on the relevant jurisdiction’s documentation requirements—however extensive they may be. Most industrialized nations have enacted rules similar to IRC Section 482.