Crowe Horwath International
Global Transfer Pricing Services
Audit | Tax | Advisory
www.crowehorwath.net
Crowe Horwath International
Transfer Pricing
Crowe Horwath International’s Transfer Pricing practice provides
economic consulting services in connection with tax issues arising
from transactions among controlled parties. As the objective of
“transfer pricing” is to determine whether intercompany transfers
of tangible and intangible goods, cost-sharing, financial/loan
transactions, and services transactions are consistent with the
arm’s length standard, we can provide transfer pricing services to
meet client needs with respect to:
■ Compliance
■ Strategic Planning
■ Implementation
■ Audit Defense, Litigation Support, and Dispute Resolution
Through Crowe Horwath International’s network of firms, we
have extensive resources worldwide to assist clients with their
transfer pricing needs. Crowe Horwath International’s service
offerings can provide support for intercompany transactions in
both local and foreign jurisdictions. Our Transfer Pricing specialists
have extensive experience working with other members of Crowe
Horwath International as well as different lines of service to provide
integrated solutions to pricing issues.
Service Offerings:
To meet the increasing sophistication of tax authorities with respect
to transfer pricing regulations and penalties, our transfer pricing
specialists provide economic consulting services in a number of
specific areas, as follows:
■ Compliance
Preparation of documentation to comply with local country
requirements and/or penalty protection
Provide diagnostic evaluation of current transfer pricing
policies and documentation
Work with advisors to develop required, country-specific
documentation
Evaluate Transfer Pricing risk on transactions for M&A due
diligence and tax provision purposes
Review analyses prepared by in-house tax departments or
outside tax consultants in order to provide an objective, third
party opinion
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■ Strategic Planning
Plan efficient and supportable transfer pricing policies to
optimize worldwide tax results within the limits of governing
regulations
Work with Crowe Horwath International member’s tax groups
to establish corporate and pricing/profitability structures for
existing and new intercompany transactions
Evaluate the impact of new and/or proposed transfer
pricing regulations, and establish policies and structures in
consideration of such regulations
Evaluate the functions performed, risks assumed, and
intangible assets employed for consistency with historical and
expected financial results
Prepare and/or analyze cost-sharing arrangements to evaluate
compliance with regulations
Prepare and/or analyze Advanced Pricing Agreements
between clients and local country tax authorities to limit audit
exposure for open and future tax years
Evaluate global profit alignment and supply-chain strategies
and opportunities
■ Implementation
Provide taxpayers with supportable policies that do not cause
unnecessary administrative and management burdens
Implement transfer pricing policies
Provide comments on intercompany agreements
Compute transfer pricing profitability for each party to a
transaction
Provide guidance related to accounting/tax system outputs
to compute transfer prices and effectively manage transfer
pricing policies
■ Audit Defense, Litigation Support, and Dispute Resolution
Provide, where allowed, expert testimony and transfer pricing/
economic analyses in support of audit defense or litigation
Participate in negotiations with local country tax authorities
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About Crowe Horwath International
Crowe Horwath International is ranked among the top 10 global accounting networks with more than 150 independent
accounting and advisory services firms in over 100 countries around the world. Crowe Horwath International’s member firms
are committed to impeccable quality service, highly integrated service delivery processes and a common set of core values that
guide decisions daily. Each firm is well-established as a leader in its national business community and is staffed by nationals,
thereby providing a knowledge of local laws and customs which is important to clients undertaking new ventures or expanding
into other countries. Crowe Horwath International member firms are known for their personal service to privately and publicly
held businesses in all sectors and have built an international reputation in the areas of audit, tax and advisory services.
Client References Available Upon Request
For more information, please contact us at:
Australia
Roger Penman
roger.penman@crowehorwath.com.au
+61 2 9619 1693
India
V. Raghavendran
raghavendran.v@crowehorwath.in
+91 (22) 6631 1480
Russia
Igor Dines
id@rbsys.ru
+7 (495) 967 6838
Austria
Iris Burgstaller
Iris.Burgstaller@tpa-horwath.com
+43 1 588 35 306
Indonesia
Army Djatipraetya
army.djatiprasetya@crowehorwath.co.id
+62 21 2553 5650
Singapore
Penelope Velten
penelope.velten@crowehorwath.com.sg
+65 6223 7757
Brazil
Leandro Cossalter
leandro.cossalter@crowehorwath.com.br
+55 11 3372 3733
Italy
Michele Ghiringhelli
michele.ghiringhelli@crowehorwath.it
+39 02 806731
South Africa
Kent Karro
kent.karro@crowehorwath.co.za
+27 21 481 7000
Canada
Neil Maisel
neil.maisel@crowesoberman.com
+416 963 7116
Japan
Hiromasa Watanabe
h-watanabe@horwathsakura.com
+81 3 3292 4444
Spain
Jesus Romero
jesus.romero@crowehorwath.es
+34 93 2448900
China
Michelle Liu
liushuyan@chcncpa.com
+86 (10) 8821 9191
Korea
Hyung Soo Kim
hs.kim@crowehorwath.co.kr
+82 2 3166 630
Turkey
Elvan Karakus
elvan.karakus@crowehorwath.com.tr
+90 212 267 10 01
France
Veronique Habe
vhabe@fidurevision.fr
+33 8944 5555
Malaysia
Army Djatipraetya
army.djatiprasetya@crowehorwath.co.id
+62 21 2553 5650
United Arab Emirates
Zayd Maniar
zayd.maniar@crowehorwath.ae
+971 4 4473951
Germany
Wolfgang Kirschning
wolfgang.kirschning@crowehorwath-rwt.de
+49 7121 489 265
Mexico
Daniel Cano
daniel.cano@crowehorwath.com.mx
+52 01 (55) 5343 9611
United Kingdom
Paul Fay
paul.fay@crowecw.co.uk
+44 (0) 20 7842 7163
Hong Kong
Wilson Tam
wilson.tam@crowehorwath.hk
+852 2894 6888
Poland
Damian Kubis
damian.kubis@tpa-horwath.pl
+48 61 855 97 91
United States
Barry Freeman
barry.freeman@crowehorwath.com
+1 (212) 572 5597
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Crowe Horwath International is a leading international network of separate and independent accounting and consulting firms that may be licensed to use “Crowe Horwath” or “Horwath” in
connection with the provision of accounting, auditing, tax, consulting or other professional services to their clients. Crowe Horwath International itself is a non-practicing entity and does not
provide professional services in its own right. Neither Crowe Horwath International nor any member is liable or responsible for the professional services performed by any other member.
© 2012 Crowe Horwath International.