Overview

In the world of international commerce, where goods, services, intellectual property, and capital flow seamlessly across borders, transfer pricing plays a critical role in ensuring both compliance and operational integrity. At Gallant & Toole Inc., we offer end-to-end Transfer Pricing Services that meet the rigorous demands of today’s regulatory environments—while enabling our clients to operate strategically, transparently, and with confidence. Transfer pricing refers to the pricing of transactions between related entities within a multinational group. These may include the sale of products, provision of services, royalty payments for intellectual property, or inter-company financing. Regulators across the globe—including the IRS, CRA, and tax authorities across the EU, UAE, and Asia—require these transactions to be conducted at arm’s-length: that is, priced as if the parties were unrelated and transacting under normal market conditions.

Getting transfer pricing right is not just about avoiding penalties—it’s about demonstrating the substance of your operations, defending your value creation, and maintaining reputational integrity across jurisdictions.

Our Approach:

At Gallant & Toole, our transfer pricing solutions are built on three pillars: compliance, substance, and strategy.

• Compliance ensures your transfer pricing policies meet global standards, including OECD guidelines, local statutory requirements, and documentation mandates.

• Substance validates that your pricing aligns with where value is actually being created—supporting your business model and functional profile.

• Strategy allows you to use transfer pricing not just as a risk management tool, but as a lever to optimize global tax efficiency and operational performance.
  

Our methodology is inspired by Big 5 best practices, but with the personalized attention and confidentiality that Gallant & Toole is known for. We design robust pricing policies, conduct economic benchmarking studies, prepare audit-ready documentation, and offer proactive planning that evolves with your business.

When You Need Transfer Pricing Support:

You may benefit from our transfer pricing services if your business:

• Operates in multiple tax jurisdictions

• Has subsidiaries, branches, or affiliates transacting with each other

• Holds or licenses valuable intellectual property

• Provides centralized services (e.g., management, IT, R&D) to group companies

• Is entering into or restructuring inter-company financing arrangements

• Is facing scrutiny from tax authorities, audits, or advance pricing agreement (APA) negotiations

• Needs to justify profit allocation in line with economic substance

Why It Matters:

Failure to implement compliant transfer pricing policies can result in:

• Double taxation due to adjustments by local tax authorities

• Heavy penalties for lack of documentation or misstatements

• Lengthy audits and disputes that divert valuable resources

• Reputational risk that may affect investor confidence and market positioning
  

With tax authorities around the world increasingly collaborating and sharing data through frameworks like BEPS and CbCR (Country-by-Country Reporting), businesses must now demonstrate a much deeper level of transparency and justification for how profits are allocated across borders.

Why Gallant & Toole:

•  OECD-Aligned Expertise: Deep familiarity with global transfer pricing frameworks

•  Cross-Border Sensitivity: Specialization in U.S., Canada, UAE, and other key markets

•  Tailored, Audit-Ready Documentation: Master file, local file, benchmarking, and functional analysis

•  Big-Firm Rigor, Boutique Service: Strategic insights with a white-glove client experience

•  Proactive Risk Management: Identify exposures before they become liabilities

Let’s Build a Globally Defensible Transfer Pricing Strategy:

At Gallant & Toole, we work with businesses and high-net-worth clients to design, document, and defend their inter-company pricing strategies with precision and foresight. Whether you’re launching in a new region, undergoing a corporate restructure, or facing audit scrutiny, we help you stay compliant while protecting the value you’ve built.

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