Transfer Pricing Valuation Services
Transfer pricing refers to the pricing of contributions (assets, tangible and intangible,
services, and funds) transferred within an organization. For example, goods from the production
division may be sold to the marketing division, or goods from a parent company may be sold to a
foreign subsidiary. Since the prices are set within an organization (i.e. controlled), the
typical market mechanisms that establish prices for such transactions between third parties
may not apply. The choice of the transfer price will affect the allocation of the total profit
among the parts of the company. This is a major concern for fiscal authorities who worry that
multi-national entities may set transfer prices on cross-border transactions to reduce taxable
profits in their jurisdiction. This has led to the rise of transfer pricing regulations and
enforcement, making transfer pricing a major tax compliance issue for multi-national companies.
Recent Transfer Pricing related engagements performed by members of Cambridge Partners include
- The valuation of patented and unpatented manufacturing technology to be
transferred to India
- The valuation of inter-company licensed trademarks
- Establishment of arm's length prices for product shipped to various related Canadian distributor dealers
- The valuation of digital media technology to be transferred to Japan
Cambridge Partners can assist you in the valuation of your assets as part of your IRS Section 482
and international Transfer Pricing Strategy. If you would like additional assistance or would like to
discuss a valuation for purposes of Transfer Pricing, please contact Cambridge
Partners & Associates for an initial evaluation consultation.
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