Transfer Pricing / 转移定价

Transfer Pricing



Globalization is exciting. You can enjoy genuine Chinese food in Shanghai on Saturday and then come back for Sunday morning worship. As global trade increases, multinational enterprises are confronted more and more with complex and potentially expensive issues associated with transfer pricing. We are ready to help.



The Internal Revenue Service is concerned about revenue loss as a result of foreign corporations employing transfer pricing, and is vigorously tracking cross-border transactions between related-party entities. Failure to maintain the proper documentation can often result in adjustments, penalties and interest.



We have been preparing transfer pricing contemporaneous documentation and benchmarking studies for many clients for many years, following IRS Section 482 regulations and OECD guidelines, utilizing Osiris global database. IRC § 482 regulations are fully consistent with OECD guidelines, centering on the application of the arm’s length principle.



Following related provisions, we perform functional analysis and comparability analysis, assessing risk factors, economic conditions, and the nature of the involved transactions. We carefully select the best method among comparable uncontrolled method, resale price method, cost plus method, comparable profits method, profit split method, and other unspecified methods. We evaluate the results of the arm’s length range to increase reliability and meet government requirements.



The IRS requires upfront compliance with the arm’s length principle. Taxpayers are required to contemporaneously document the related-party transactions and provide the documentation to the IRS within 30 days upon request. Please feel free to contact us with any question. We are glad to lend our expertise to your global operation. Additionally, our wide and solid network in China enables us to assist you doing business in China.