WTP Advisors was retained by a UK specialty chemicals company to advise them on transfer pricing considerations associated with the transfer of an existing US distribution business to a new US subsidiary. Our analysis disclosed that the UK parent company had invested considerable resources in developing US contract manufacturing resources and customer lists, and we prepared transfer pricing documentation that supported the conclusion that these investments should be taken into consideration in establishing the intercompany pricing between the UK and US. Our transfer pricing analysis led to significant modification of the client’s transfer pricing model and reduction of its global effective tax rate.
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