We combine technical rigor with clear communication. Our international tax specialists work closely with your finance, accounting, and legal teams to build robust documentation that is aligned with your group’s global strategy.
The process covers diagnostics, pricing models, intercompany policy design, and deliverables in a format that meets OECD, IRS, and local-country requirements.
Master File
A global document describing the group’s structure, intercompany operations, intangibles, financing, and value chain, prepared in line with OECD guidelines and designed to support multiple jurisdictions.
Local File
A country-specific report that includes functional analysis, method selection, and comparable benchmarking for each relevant type of intercompany transaction (services, royalties, financing, distribution, manufacturing, and more).
Country-by-Country Report (CbCR)
A consolidated report of revenue, profit, headcount, and taxes paid by jurisdiction, required for multinational groups that exceed the thresholds established by the OECD and local tax authorities.
Transfer pricing policy
A documented policy that defines target margins, allocation criteria, and operating rules, ensuring consistent pricing month after month and facilitating implementation in your accounting and finance systems.
Risk analysis and planning
Proactive assessment of potential adjustments, gray areas, and exposures in front of tax authorities, together with strategies to mitigate those risks in advance (year-end adjustments, functional reallocations, advance pricing agreements where appropriate).
Audit and controversy support
Technical and documentary assistance during transfer pricing reviews, with arguments grounded in market data, international guidance, and the group’s actual economics, as well as support in negotiations and dispute resolution.
At Guillen Pujol CPAs, every engagement begins with a comprehensive review of your intercompany transactions. We analyze contracts, functions, assets, and risks for each entity involved in the value chain.
Based on this functional analysis, we apply recognized transfer pricing methods under OECD and IRS rules—from the Comparable Uncontrolled Price (CUP) method to the Transactional Net Margin Method (TNMM)—selecting the method that best reflects the group’s economic reality and the profile of each jurisdiction.
This service is designed for corporate groups, holdings, companies with international subsidiaries, and entities with material intercompany operations that must demonstrate compliance to tax authorities in the U.S. and abroad.
It is also critical for growing businesses entering new markets that need to establish transfer pricing from the outset, and for family-owned or corporate groups with multi-country structures seeking to avoid costly adjustments, double taxation, and penalties.
Frequently Asked Questions
What is transfer pricing?
Transfer pricing refers to the prices charged between entities of the same group for transactions involving goods, services, loans, royalties, or other intangibles. These prices must respect the arm’s-length principle—meaning they should be consistent with what independent parties would have agreed.
Why is documentation so important?
Tax authorities require evidence that intercompany transactions comply with the arm’s-length principle. High-quality documentation reduces the risk of adjustments, penalties, and double taxation and provides a strong foundation for defending your position in an audit.
Which reports are required?
Depending on the jurisdiction, you may be required to prepare a Master File, a Local File, and a Country-by-Country Report (CbCR) in accordance with OECD guidance, the IRS regulations, and local transfer pricing rules.
Which methods do you use for the analysis?
We apply internationally accepted methods—CUP, Resale Price, Cost Plus, TNMM, and Profit Split—depending on the nature of the transactions, available data, and the functional profile of each entity involved.
Can you support us during audits or disputes?
Yes. We support clients during audits and reviews, drafting technical responses, quantifying adjustment scenarios, and building a defensible position in front of tax authorities, including support in negotiations and dispute resolution processes.
Aligned transfer pricing, mitigated risks, and defensible compliance
Strengthen your group’s tax position with defensible analyses, comprehensive documentation, and pricing strategies that can withstand scrutiny. Schedule an assessment with our international tax transfer pricing team and ensure compliant, durable policies across all your jurisdictions.
Guillen Pujol CPA P.A
6161 Waterford District Dr., Suite 475 Miami, FL 33126
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Guillen Pujol CPA P.A
6161 Waterford District Dr., Suite 475 Miami, FL 33126
Guillen Pujol CPA P.A
6161 Blue Lagoon Dr.Ste 475, Miami, FL 33126
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