Transfer Pricing Expert Witness Timeline

Typical timeline

• Retention and records intake 1 to 2 weeks
• Functional analysis and comparables 4 to 8 weeks after records are received
• Draft and final report 2 to 3 weeks after the analysis
• Deposition and trial support As scheduled by counsel and the tribunal

What the engagement delivers

We issue the final report in the form the forum requires and provide deposition and trial testimony, critique of the opposing transfer pricing analysis, and updated calculations as the record develops.

Also for this service

• Transfer Pricing Expert Witness
• Cost and fee structure for transfer pricing
• Engagement process for transfer pricing

Guides and methods

• Transfer Pricing Disputes Explained: The Arm's Length Standard and Section 482 - Guide
• Transfer Pricing Methodology - Method
• Intercompany Royalty Rates in Litigation - Guide

References

• 26 U.S.C. sec. 482 (allocation of income and deductions among taxpayers). law.cornell.edu
• Treas. Reg. sec. 1.482-1 (allocation of income and deductions among taxpayers). ecfr.gov
• OECD. (2022). OECD transfer pricing guidelines for multinational enterprises and tax administrations 2022. OECD Publishing. doi.org
• Tax Ct. R. Prac. & Proc. 143(g) (expert witness reports). ustaxcourt.gov
• Internal Revenue Service. (2020). Transfer pricing examination process (Publication 5300, Rev. 9-2020). U.S. Department of the Treasury. irs.gov