WTP Advisors has acquired the transfer pricing and international structuring business of Michael J. Flaherty LLC.
The transfer pricing firm advises multinational companies on cross-border transactions. Under the terms of the acquisition, the new division will be named WTP Cross Border and will be led by Michael Flaherty, a transfer-pricing lawyer with over 20 years’ experience. Financial terms were not disclosed.
“The U.S. is the grandfather of transfer-pricing law and interpretation, and Michael is an expert in the field,” said WTP Advisors partner Ian Boccaccio in a statement. “Given the enormous growth in this area, we are excited to have him on board to help clients optimize their tax positions through strategic transfer pricing planning.”
Transfer pricing refers to the way in which a multinational company prices goods, services, intangibles and capital to and among its foreign affiliates. Transfer pricing also has become one of the most contentious areas of reporting between taxpayers and the relevant tax regulators, because each country in which a company’s affiliate is located has a vested interest in seeing that earnings and taxes are fairly reported in its jurisdiction.
Flaherty noted that the U.S. has played an important role in developing global awareness and understanding of transfer pricing, and the rich history of U.S. experience in developing transfer pricing through case law and regulatory interpretation provides a deep well of experience from which WTP Cross Border will be able to draw. He pointed to guidelines from the Organization for Economic Cooperation and Development.
“The good news for multinationals is that most countries look to the OECD Transfer Pricing Guidelines for their approach to transfer pricing, and that provides some consistency in both interpretation and documentation requirements,” said Flaherty.
In addition, because the U.S. has been instrumental in the development of transfer pricing regulations, including the formulation of the OECD Guidelines, Flaherty feels that this long history working with transfer-pricing concepts puts WTP Advisors in a good position to offer a global approach to transfer pricing.
