In every engagement Thompson Dunavant Global Solutions attempts to identify value added tax minimization strategies where they exist or may be discovered.  Transfer pricing planning can be achieved through rationalization and placement of risk, functions, and asset utilization which dictate the allocation of income and deductions.  

We have been able to identify tax planning and minimization strategy opportunities to absorb excess net operating losses and excess foreign tax credit positions.  Utilizing transfer pricing, we have also been able to assist in tax planning and minimization through Subpart F planning by identifying the best place to pass title on tangible property, dividend payment planning based on a rationalization of risks, functions, and asset utilization, and intangible property migration strategies developed by identifying favorable countries for the development of second generation intangible property and the discovery and quantification of soft forms of intangible property.  We have also been able to assist multinationals in their tax minimization efforts via structuring and restructuring of their business operations with regard to Section 199 of the American Jobs Creation Act of 2004 and various tax treaties in conjunction with transfer pricing planning.

The placement of risks, functions, asset utilization, and other business operations can have a material impact on tax planning and tax minimization opportunities.  If your multinational firm has business operations included in the list below, it is a good candidate to achieve tax minimization through transfer pricing planning.

  • The existence and placement of intangible property and intangible property development
  • The existence and placement of R&D functions
  • The existence and placement of the provision of services
  • The existence and placement of distribution functions
  • The existence and placement of manufacturing and contract manufacturing operations
  • The existence and placement of a physical presence and permanent establishment planning
  • The existence and placement of risks, functions, and asset utilization
Recent regulatory changes concerning transfer pricing issues such as intercompany services provide ideal tax planning opportunities for multinational firms that engage in intercomany or related party service transactions.