Transfer Pricing Study Transfer pricing is one of the most important aspects of IRS international examination in terms of technical complexity and in terms of the dollar amount involved. Recently, countries worldwide are following a transfer pricing enforcement trend set by the IRS. Even though it may sound unnatural calculating theoretical transfer prices, for most taxing authorities, transfer pricing study using uncontrolled comparables is the most reasonable approach to determine the proper taxable income for multinational companies who can intentionally shift the tax obligations from one country to another. Furthermore, U.S. Treasury regulations impose very harsh penalties if companies cannot meet the transfer pricing documentation requirements or have substantial tax adjustments due to inappropriate transfer pricing. Using our transfer pricing expertise and experiences, we provide the best transfer pricing strategy and analysis for multinational corporations in the most customer friendly manner along with the most competitive service fee. Advance Pricing Agreement For the companies who want certainty in the future on transfer prices and related taxable income, we strongly recommend clients to secure the Advance Pricing Agreement (APA) between IRS and the taxpayer or among multiple taxing authorities and the taxpayer. There are many advantages of securing an APA for multinational companies. An APA reduces the risk of double taxation, saves costly litigation expenses, eliminates the hassle of transfer pricing audits, and it even resolves the old burdensome tax dispute with the IRS or with other taxing authorities. Not only our experts have the most hands-on APA experience and in-depth knowledge of all aspects of APA, but also our senior staff provides the APA service to our clients in person at all time.