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Transfer Pricing

Transfer pricing has become a significant area of focus for tax authorities around the globe as countries seek more effective ways to protect their tax bases. Authorities are focusing more widely and intensely on transfer pricing issues, and more and more countries are requiring companies to substantiate and document their transfer pricing practices.

Our Approach

Our team has served many prominent multinational clients, providing tailored transfer pricing solutions based on the company’s needs. We approach every project in a consultative and collaborative manner, with the goal of helping businesses reduce risk by establishing economically supportable and practical transfer pricing policies.

Our membership in Moore Global Network allows us to examine your transfer pricing issues from all angles with assistance from our partner firms across the globe. Moore Global has 650 member offices throughout 100 countries, so wherever your issues arise, we have experts who can help.


Transfer pricing can be a very complicated endeavor. We provide tax and consulting services to help you build, manage, document, review and defend your transfer pricing policies and processes.

  • Planning:  To succeed globally, you need to develop economically sound and sustainable transfer pricing policies. Our experts can provide transfer pricing advice for all types of planning arrangements, including services, tangible and intangible assets transferred during a business restructuring, financial transactions and licensing.
  • Compliance and Documentation: We prepare documentation studies and pricing analyses for all types of transactions, including tangible and intangible goods transactions, intercompany service transactions, cost-sharing arrangements and financial transactions for U.S. and foreign compliance purposes.
  • Policy Design and Implementation: We can help you develop and implement policies and procedures for setting, monitoring and documenting intercompany tax transactions.
  • Financial Statement Support Services: We have extensive experience assisting companies with the preparation of alternative tax positions for FIN 48 analyses and relevant supporting memorandums.
  • Tax Controversy and Dispute Resolution: Our team can help resolve transfer pricing disputes through various services, including avoidance techniques, resolution alternatives, strategic planning, risk management, analysis and disclosure.

Moore Global Network

Moore Global NetworkArmanino is a member of Moore Global Network*, one of the largest international networks of firms in the world. This network provides us, and by extension, our clients, with resources on the ground in nearly every corner of the globe, as well as local knowledge on legal and tax issues for various jurisdictions.

Moore Global member firms and correspondents are located across more than 650 offices and 100 countries including:

  • Africa
  • Asia Pacific Region
  • Australia
  • China
  • Europe
  • Latin America
  • Middle East Region
  • North America

*Armanino LLP is an independent member firm of Moore North America Inc. (MNA), which is itself a regional member of Moore Global Network Limited (MGNL). All the firms associated with MNA and MGNL are independent entities, owned and managed in each location. Their membership in, or association with, MNA or MGNL should not be construed as constituting or implying any partnership between them.



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