Transfer Pricing and IP Tax Transactions

Strategic Tax Planning for Intercompany Transactions and Intellectual Property

Overview

In today’s globalized business landscape, transfer pricing and IP tax strategies are essential for companies operating across multiple jurisdictions. At Lazarus, we provide strategic guidance to help businesses structure intercompany transactions and intellectual property transfers in a way that optimizes tax efficiency while ensuring compliance with complex regulations. Our expertise in transfer pricing and IP tax transactions helps clients navigate evolving tax requirements, manage risk, and achieve sustainable growth.

How We Can Help

Our comprehensive approach to transfer pricing and IP tax transactions supports businesses in establishing efficient, compliant structures for global operations. Key services include:

  • Developing tailored transfer pricing policies for intercompany transactions that align with business objectives and meet the documentation standards of tax authorities worldwide.

  • Structuring tax-efficient transfers of intellectual property, including patents, trademarks, and proprietary technology, and providing valuation guidance that meets both regulatory and market standards.

  • Designing and implementing cost-sharing arrangements that enable shared R&D investment across entities while maintaining compliance with global tax regulations.

  • Assisting clients in negotiating advance pricing agreements with tax authorities, providing certainty and reducing the risk of transfer pricing disputes.

  • Ensuring that transfer pricing and IP tax practices remain compliant with local and international regulations, including BEPS (Base Erosion and Profit Shifting) requirements and OECD guidelines.

Representative Transactions

  • Transfer Pricing Documentation for Multinational Corporation: Created transfer pricing documentation for a client with operations across 15 countries, ensuring compliance with local tax regulations and optimizing global tax positions.

  • IP Transfer for Tech Company Expansion: Advised a U.S.-based technology company on transferring IP to a European subsidiary, structuring the transaction to optimize tax efficiency and address international tax regulations.

  • Cost-Sharing Agreement for R&D: Structured a cost-sharing agreement for a life sciences company’s R&D operations, allowing multiple global entities to share costs and benefits while maintaining compliance with U.S. and international tax laws.

  • APA for Cross-Border Manufacturing: Successfully negotiated an advance pricing agreement for a manufacturing client with operations in the U.S. and Asia, reducing potential transfer pricing disputes and achieving tax certainty.

The transactions listed above include experience our attorney gained a prior firm.

Why Choose Lazarus?

  • In-Depth Transfer Pricing and IP Expertise

    Our knowledge of international tax regulations and transfer pricing practices allows us to guide clients in managing tax risks and optimizing global tax strategies.

  • Tailored, Strategic Solutions

    We develop customized strategies that reflect the specific needs of each client, ensuring that intercompany transactions and IP transfers align with business objectives.

  • Proactive Compliance and Risk Management

    We help clients stay ahead of evolving tax regulations and manage risks associated with intercompany transactions and intellectual property.

Move Forward with Confidence

At Lazarus, we provide more than just tax advice. We bring strategic insights and a results-driven approach to transfer pricing and IP transactions, helping you optimize tax outcomes and stay compliant across jurisdictions. We’re committed to being your trusted advisor in a complex global tax environment.

With Lazarus, you’re ready for what’s next.