Tax Services

Transfer Pricing

Transfer pricing is a key component of tax planning for multinational companies. Make sure your profit allocation strategy is contributing to overall profitability, not creating unnecessary drag on the bottom line.

Our Approach

Clear, Consistent and Centered on Your Business

Leading a multinational organization is a huge responsibility. You’ve got a lot on your plate without trying to keep tabs on the transfer pricing rules for U.S. and foreign countries. Failure to comply with these transfer pricing rules and the Base Erosion and Profit Shifting (BEPS) initiatives can cost your business everything.

When key information can mean the difference between profitability and crippling penalties, you can’t afford to take risks.  Be sure you’re covered, with critical information and transfer pricing support that helps you remain confident and competitive.

SaaS Company Reduces International Taxes With Revised Transfer Pricing Method
Case Study
SaaS Company Shrinks International Taxes With Revised Transfer Pricing
A growing SaaS company was leaving significant profits on the table with international sales of software. Our international tax experts were able to yield significant annual tax savings for them without causing disruptions to their operations.


Meeting Your Needs

Making tax-efficient transfer pricing choices while keeping your company on the right side of the law requires the right information at the right time. Gain access to the latest tax, accounting and business insights from the brightest minds in the profession. From arm’s-length adherence to dealing with debt and intangibles, we bring you the services you need to inform strategic business decisions and remain in compliance with transfer pricing rules as you expand your global footprint.

With constantly changing laws in a dynamic global business environment, your business needs a tax-efficient approach to transfer pricing that takes advantage of every opportunity to enhance your bottom line. Comprehensive transfer pricing planning services help you minimize tax liability without risking noncompliance.

Compliance and Documentation

Can you support your current transfer pricing policies? International tax authorities are closely scrutinizing compliance with transfer pricing regulations. Get an in-depth understanding of the latest rules and comprehensive assistance in preparing reports and documentation that can withstand the rigors of a potential audit.


Transfer pricing is a complex issue, and a plan is only as good as its implementation. We help you put your plan into action, providing practical support with systems, processes and policies to help you transform plans into greater profitability.

Financial Statement Support

Even if your transfer pricing position is fully supportable, your financial statements may not show that. Financial statements themselves can also fail to comply with your company’s transfer pricing policies. Our advisors help ensure your accounting fully aligns with the law and completely and correctly portrays all transfer pricing.

Dispute Resolution

No one looks forward to a transfer pricing dispute with tax authorities, but audits don’t always signify a problem. Our experienced analysts support you through the entire audit process, providing informed analysis and presenting a well-supported defense of your position to help minimize the risk of tax adjustments and penalties.

Read More
Nghi Huynh - Partner, Tax - San Jose CA | Armanino
Nghi has more than 16 years of experience in transfer pricing, tax planning projects, research and audit.

San Jose, CA
Jon Davies - Partner, Tax - San Jose CA | Armanino
Jon specializes in international tax structuring, cross-border transactions, transfer pricing, and merger acquisition.

San Jose, CA
News & Insights
Top Tax Issues for Buyers and Sellers in Today’s M&A Market
Get clarity on the tax questions that can impact your transaction’s value in a less forgiving marketplace.

January 10, 2024
SaaS Company Reduces International Taxes With Revised Transfer Pricing Method
Case Study
The new tax methodology solved challenges in foreign distribution entities and provided earnings predictability.

December 22, 2021
M&A Transfer Pricing Analysis for Indian Subsidiary Frees $700K in Escrow
Case Study
When M&A due diligence found a lack of transfer pricing documentation, the buyer withheld $1.25M.

April 19, 2021
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