Economic and Valuation Support for Transfer Pricing Examinations
The Valuation Group provides transfer pricing audit support for matters involving related-party pricing, inter-company services, royalties, intangible asset transfers, affiliated-company transactions, benchmarking analysis, and cross-border documentation review.
Our work supports companies, CPAs, tax advisors, attorneys, CFOs, and advisory teams that need to review, organize, explain, or supplement the economic support for inter-company pricing positions.
Why The Valuation Group
Transfer pricing review often turns on whether the related-party pricing is supported by the transaction documents, functional analysis, financial evidence, comparable data, valuation assumptions, and economic substance of the arrangement.
Our audit-support work focuses on the evidence reviewers are likely to test: transaction documents, pricing methods, functional analysis, comparable data, financial inputs, royalty support, valuation assumptions, and the commercial reasonableness of the position.
We review transfer pricing documentation involving inter-company services, royalties, intellectual property licenses, related-party transfers, financing arrangements, management fees, and affiliated-company transactions.
Our work may address the transaction description, pricing method, functional analysis, comparable data, financial inputs, assumptions, documentation quality, and the relationship between the economic analysis and the pricing conclusion.
Transfer pricing matters may require organized schedules, financial analysis, valuation support, benchmarking reviews, royalty analyses, or explanations of related-party pricing assumptions.
The Valuation Group provides support to assist the professional team in preparing for review, responding to questions, evaluating exposure, and identifying areas that require additional analysis or documentation.
Transfer pricing audit support may involve review of comparable company selections, profit-level indicators, margins, royalty rates, royalty bases, comparable license agreements, service markups, and other market evidence.
We analyze whether the support presented is consistent with the transaction, the parties involved, the functions performed, the assets used, the risks assumed, and the economic benefit transferred.
Audit review may focus on whether related-party transactions reflect economic substance and are supported by commercially reasonable terms.
The Valuation Group analyzes the transaction structure, financial records, inter-company agreements, pricing method, market evidence, and business context surrounding the arrangement.
