MDW CONSULTING INC.


Transfer Pricing Services

MDW helps businesses build, implement, document, review and defend transfer pricing policies and strategies. We use the most appropriate transfer pricing methods based on the facts and circumstances including the Comparable Uncontrolled Price Method (CUP), Resale Price Method, Cost Plus Method, Profit Split Method, Transactional Net Margin Method (TNMM), Comparable Profits Method (CPM) and other methods including valuation techniques.

MDW provides expert services for Related Party Transactions

  • Sale of Product
  • Provision of Services
  • Acquisition, license and use of Intellectual Property
  • Cost Contribution / Sharing Arrangements
  • Financial Transactions

BUSINESS RESTRUCTURING

Matthew Wall’s unique skill set as a Chartered Professional Accountant (CPA, CA) and Chartered Business Valuator specializing in transfer pricing since 1996 uniquely qualifies him to assist with business restructuring.

DOCUMENTATION

Most taxpayers have transfer pricing documentation for their related party transactions, which has three purposes: prepared annually when filing the tax form for related party transactions; given to tax authorities at the start of an audit; and, to mitigate the risk of transfer pricing penalties.

DISPUTE RESOLUTION

MDW has a unique approach and invaluable experience defending companies at all stages of an audit, objection, appeal, request for Competent Authority, and Advanced Pricing Agreement.

EXPERT TESTIMONY

Matthew Wall has appeared as an expert witness on transfer pricing and continues to be sought after for this type of work by legal counsel for both the appellant / plaintiff and respondent / defendant in the courts of law.

Frequently Asked Questions

Transfer pricing involves setting a structure and price for transactions between business units, divisions or entities (“related parties”) within a company.

Profits are shifted if the price for a transaction is too high, or too low.

The tax authorities care if profits are shifted to related parties in different countries, resulting in incorrect taxes paid in one or more countries. As such, transfer pricing is the single most important issue under audit. Others care too!

Section 247 of the Income Tax Act defines the transfer pricing rules in Canada for transfer pricing adjustments, penalties, documentation, etc.
Information Circular 87-2R: International Transfer Pricing provides guidance on the application of the transfer pricing rules. The Transfer Pricing Memoranda series provides further guidance and examples on specific issues. Details are available on the Canada Revenue Agency website.

Section 482 of the Internal Revenue Code defines the rules for applying transfer pricing in the U.S. Section 6662 of the Internal Revenue Code defines the transfer pricing penalties and documentation requirements in the U.S. Details are available on the Internal Revenue Service website.

The Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations published by the Organization of Economic Cooperation and Development (OECD Guidelines) is the international standard used by most tax authorities around the world. Details are available on the OECD website.