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Multidisciplinary Valuation and Corporate Advisory Firm Transparently Serving the Full Range of Attorneys, Asset Managers, CFOs, and CPAs TM

NAV Valuation & Advisory LLC - Alternative Investment Valuation & Financial Advisory Firm

Alternative Investment Valuation and Financial Advisory Firm Transparently Serving the Full Range of Asset Managers, Attorneys, CFOs, and CPAsTM

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Justin Kuczmarski,

Tax Valuations: Transfer Pricing Opinions


Sound transfer pricing practice implies a comprehensive strategy of planning and compliance to meet all business objectives, from corporate strategy to operational design. Our transfer pricing services include the defense and valuation of intercompany pricing.

NAV’s solutions help both clients' business objectives and the requirement for an arm's length standard that is imposed by national tax authorities.  

Our valuation experts possess deep experience defending their transfer pricing economic analysis before IRS engineers, the official term for IRS valuation specialists. We also offer a limited analysis called a situation scan. NAV's team delivers transfer pricing situation scans to understand the tax and economic structure of a multinational. This situation scan is generally not offered by large accounting and advisory firms who prefer to render a more expensive formal opinion. However, for many clients the situation scan may suffice, and we provide clients with this truncated service offering to transparently and efficiently communicate high-level results.

Some of the benefits of an independent transfer pricing study include:

  • Top-level advisory with FIN 48 requirements for private companies 
  • Analysis of potential international tax exposure for use in strategic tax planning  
  • Identification of key focus areas for potential analysis under IRS Section 482 
  • Scan of contemporaneous work paper documentation
  • Communication with client on potential tax structuring alternatives

Client Example # 1: Transfer Pricing Situation Scan & Eventual Full Economic Opinion


An Irish software developer established a New York sales office to introduce its products within North America. NAV's international transfer pricing team assisted in identifying high-value services subject to arm’s length transfer pricing in addition to documenting low-margin services capable of pricing at cost. This two-prong approach was designed to comply with the new IRS transfer pricing services regulations introduced in 2008.

Client Example # 2: Transfer Pricing Situation Scan 


Financial services firm with a leading money-market operation approached our professionals to analyze their international tax exposure from capital transactions between New York and London.

NAV's team researched potential broker-dealer transfer pricing exposure and reviewed the client’s existing tax consulting study to verify the validity of international transactions. Our team of experts then helped examine which intercompany services could benefit from a transfer pricing economic opinion and which services did not require further analysis.