KW Economics provides transfer pricing analysis for cases venued in San Juan, Puerto Rico. For a business based in San Juan, the analysis runs on the group's own intercompany agreements, financial statements, and ledger and on comparable transactions and companies selected for the transactions at issue rather than for the city, so San Juan-area market conditions enter only where a comparability adjustment calls for them. Each transaction, screen, and adjustment is documented so the arm's length result can be tested at deposition. Civil claims arising in San Juan are typically heard in the Court of First Instance (Tribunal de Primera Instancia) sitting in San Juan Municipio. Deposition and trial testimony are available for San Juan matters, in person or by remote appearance where the forum allows.
A federal tax dispute for a business based in San Juan is heard in the United States Tax Court, which holds trials in cities across the country, or, on a refund claim, in a federal district court or the Court of Federal Claims; a dispute over Puerto Rico's own tax follows its administrative and appeal process. Either side.
Economic analysis and expert testimony on whether the prices charged between companies under common control, for goods, services, the use of intangibles, and intercompany loans, meet the arm's length standard: the result unrelated parties would have reached in the same transaction under the same circumstances. The work delineates the transactions from the intercompany agreements and the companies' actual conduct, selects the most reliable method, documents the comparables and the arm's length range, and quantifies what the price moved, for tax examinations and appeals, Tax Court and refund litigation, state tax disputes, and commercial, shareholder, and divorce cases.
KW Economics serves counsel throughout San Juan and the surrounding San Juan Municipio area. Our economists test the prices charged between related companies against the arm's length standard, from the group's own intercompany agreements and financial records and from comparables selected for the transactions at issue, with San Juan-area market conditions entering only where a comparability adjustment calls for them, and are familiar with the forums and disclosure rules that apply to transfer pricing disputes involving Puerto Rico businesses.
Transfer pricing analysis for San Juan matters is directed by Christopher Skerritt, M.Ed., MBA, Chief of Economic Services, who is available to testify to it.
KW Economics offers complementary economic damages services for San Juan cases.
We also provide transfer pricing analysis in these Puerto Rico communities.
Yes. KW Economics provides transfer pricing analysis for attorneys handling matters venued in San Juan, Puerto Rico, for plaintiff and defense counsel across the case mix common to San Juan matters.
The intercompany agreements and their amendments, the transfer pricing documentation for each year at issue, legal-entity and segmented financial statements, and the general ledger detail of the intercompany accounts, together with the operating records and interviews the functional analysis rests on. The comparables come from financial data on independent companies and from license agreements between unrelated parties, selected for the transactions at issue rather than for the city.
KW Economics provides transfer pricing expert reports for tax and civil forums, preliminary reviews of a group's documentation or of a proposed adjustment, reviews and rebuttals of opposing transfer pricing analyses, and deposition and trial testimony. The appropriate deliverable depends on the forum and the case posture.
Request a consultation on Transfer Pricing in San Juan or call (201) 343-0700. Plaintiff and defense counsel.