With one of the world’s premier transfer pricing law practices, our interdisciplinary team of lawyers, economists and accountants provides clients with pragmatic, cost-efficient and comprehensive solutions to their transfer pricing needs. We are sought regularly by major multinational enterprises to handle transfer pricing planning and advance pricing agreement (APA) and controversy matters, including controversy cases that other professional advisors have not been able to resolve.
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.
A US multinational engineering and construction firm with successfully settling a significant transfer pricing and international tax controversy matter in administrative and US Tax Court proceedings, where original proposed adjustments were eliminated and the taxpayer was granted a refund
A multinational consumer goods group on a proposed tax adjustment by German tax authorities
A financial information and analytics company in US-Italy and Italy-UK competent authority cases involving proposed adjustments related to intercompany intangibles and services transactions