logo WTP Advisors is Celebrating 20 Years!

Our Personalized Approach to Delivering Services to Clients

We know how frustrating it can be to work with a firm you don’t feel confident in. That’s why you’ll never deal with entry-level staff with WTP Advisors, only seasoned professionals with substantial transfer pricing experience. Our results-oriented practice puts your needs first so you can achieve your goals efficiently and effectively.

Despite an international consensus on the arm’s length principle (Article 9, OECD Model Tax Convention*), differences in transfer pricing approaches can vary significantly between countries and result in disagreements between tax authorities and taxpayers. WTP Advisors assists clients in developing transfer pricing strategies and documentation that will identify potential risks and opportunities to mitigate the potential for double taxation associated with transfer pricing adjustments and non-deductible penalties and interest.

*The arm’s length principle is the standard most countries adhere to in establishing the correctness of the pricing of transactions between commonly controlled parties. Article 9 of the OECD Model Tax Convention.

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Our Extensive Transfer Pricing Services

When you begin working with our team, we’ll sit down with you to determine how we can help you. We’ll also take the opportunity to break down what our services entail so that you can make educated transfer pricing decisions. Our global transfer pricing services include the following:

Our Services Include:

Planning & Design

  • Global Transfer Pricing Policy
  • Risk & Opportunity Analysis
  • Services Cost Allocation
  • Intangibles Planning
  • Scenario Modeling
  • Joint Venture Support
  • Post Merger Integration

Implementation

  • Software as a Service / Process Improvement
  • Benchmarking Analysis
  • Transfer Pricing Documentation
  • International Valuation
  • Pillar 2
  • Due Diligence Review

Controversy Support

  • Audit Readiness Strategy
  • Tax (IDR) Support
  • Dispute Resolution
  • Advanced Pricing Agreements (APAs)
  • Competent Authority Support

Transfer Pricing Services You Can Rely On

At WTP Advisors, we’re passionate about helping our clients make educated decisions on their approach to managing their transfer pricing risks, and we want to do the same for you. Whether you’d like to develop sustainable tax planning strategies, defend against proposed transfer pricing adjustments by tax authorities, or simply manage transfer pricing risks, our firm is here for you. Call us today for your consultation and get the professional help you need!

WTP Advisors' Transfer Pricing Team
Expertise You Can Trust

Guy

Guy Sanschagrin, CPA/ABV

Principal, National Leader of Transfer Pricing & International Valuation Services

Guy

Bob Bamsey

Managing Director, Transfer Pricing and Valuation Services

Michael

Michael Bredahl

Managing Director, Transfer Pricing and International Valuation Services

Kash

Kash Mansori, Ph.D.

Managing Director, Transfer Pricing and International Valuation Services

Kash

Jessica Rask, CVA

Managing Director, Transfer Pricing and International Valuation Services

Palesa

Palesa Sansole, LL.M

Managing Director, Transfer Pricing and Valuation Services

Rodrigo

Rodrigo Arana

Director, Transfer Pricing and International Valuation Services

Lisa

Lauren Ludwick, JD

Director, Transfer Pricing and International Valuation Services

Lisa

Lisa Yashar, JD

Director, Transfer Pricing and International Valuation Services

Veronique

Veronique Struis

Manager, Transfer Pricing and Valuation Services

Lucas

Lucas Kinzel

Consultant, Transfer Pricing and Valuation Services

Frequently Asked Questions

Transfer pricing is the pricing of goods, services, and intangibles transferred within related entities across borders. It matters because it determines where profits are reported and taxed.

The arm’s length principle requires that related-party transactions be priced as if conducted between independent entities, ensuring fair allocation of income and tax.

The OECD recommends methods such as Comparable Uncontrolled Price (CUP), Resale Price Method, Cost Plus Method, Transactional Net Margin Method (TNMM), and Profit Split.

Governments seek to combat profit shifting and protect tax bases. Transfer pricing audits ensure compliance with local rules and OECD guidelines.

Documentation includes a master file, local file, and country-by-country report (CbCR), providing transparency into global income allocation.

Intangibles like intellectual property are difficult to value, leading to disputes and stricter guidance under OECD BEPS Actions 8–10.

APAs allow businesses to agree in advance with tax authorities on acceptable transfer pricing methods, reducing disputes and uncertainty.

Transfer pricing adjustments can alter declared import/export values, impacting customs duties and VAT.

Technology, pharmaceuticals, and finance industries face heightened scrutiny due to the heavy use of intangibles and intra-group services.

By maintaining robust documentation, aligning operations with economic substance, and proactively seeking APAs or mutual agreement procedures.