We routinely handle some of the largest transfer pricing cases around the world. Our team has established working relationships with—and has an understanding of—taxing authorities worldwide. We apply our deep knowledge of the pertinent legal, tax and economic issues to transfer pricing in the context of international tax planning, compliance and documentation, APAs and controversy, and the interface of tax/financial accounting.
Together with professional colleagues in more than 50 countries, we provide economic support, controversy support and counsel on government rulings, reporting and documentation, intangible property planning, permanent establishment theories and other issues.
Members of McDermott’s transfer pricing team are leaders in their field who have authored principal US and OECD (Organization for Economic Co-operation and Development) transfer pricing treatises, and act as standard authorities in the field of transfer pricing. We are frequently asked by the OECD to comment on transfer pricing matters and are active in the OECD Business and Industry Advisory Committee, the International Chamber of Commerce Commission on Taxation and the United States Council for International Business. Members of the team also have held high-level positions (including serving as chair) on the transfer pricing committee for the American Bar Association (ABA). In addition, members of the team lead a Transfer Pricing Discussion Group of large US- and foreign-based multinational enterprises.