About Us

Examples of Our Work


Solving Deductibility Issues in Latin America
With countless jurisdictions and policies, it can be difficult to assuage the various Latin American counterparts even within a company. And, when a US-based HQ of a Fortune 200 company tries to convince company controllers to record the corresponding service fees as deductions on their local tax return, it takes come convincing and due diligence to instill confidence and garner appropriate action.
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Global Analysis Under the New Service Regulations
The US Department of the Treasury released the final and temporary regulations for the treatment of services under Section 482 in 2006. A Fortune 100 company is concerned because they have hundreds of millions of service costs incurred among their headquarter operations in the US (world HQ), South America (regional HQ), and Europe (regional HQ) and have never performed an analysis to review and prospectively allocate these costs.
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Conducting a Complex FIN 48 Analysis of Transfer Pricing Positions
A Fortune 500 Global Marketer of Athletic Products had thousands of intercompany transactions across dozens of jurisdictions, which resulted in making transfer pricing one of the most significant parts of its FIN 48 analysis.
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Experts in the Largest Transfer Pricing Case Ever Settled
In September of 2006 The Internal Revenue Service and Glaxo SmithKline Holdings (Americas) Inc. & Subsidiaries (“GSK”) announced that they had reached a settlement involving their transfer pricing dispute.
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Teaming With In-house Transfer Pricing Department
The oil and gas industry has many challenges with respect to transfer pricing. Whether it is commodity flows from the Exploration and Production (upstream) operations to the midstream (marketing and refinery) activities to downstream (distribution and retail) activities. Ceteris helps a multinational oil and gas company manage a transfer pricing project.
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Developing, Documenting and Implementing a New Transfer Pricing Policy
Develop, benchmark, document, and implement a revised and comprehensive set of global transfer pricing methodologies.
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Incorporating New Operations
A major multinational bank is initiating a new North American business operation. The company seeks advice on arm’s length split of revenues and expenses between three major tax jurisdictions (and to provide necessary documentation).
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Option Pricing to Commercialize IP
A financial services company requests assistance in developing an option pricing model for establishing an option to purchase Intellectual Property (IP) at cost for further commercialization beyond its current internal use.
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Responding to a Short Timeframe
A specialty chemical manufacturer requests updated transfer pricing documentation for multiple countries to be performed in a very short timeframe.
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Overhauling a Global Transfer Pricing Policy
Ceteris was engaged to overhaul global transfer pricing policies to reflect changes in a US equity broker’s business model and industry economics.
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