Transfer pricing plays a central role in the operation of virtually every corporation that operates in a global market. Transfer price refers to the price at which divisions of a company transact with one another for goods or services. In theory, such prices should reflect the realities of market conditions – the price should reflect the market-bearing price at which a party would be willing to sell, at which a party would be willing to pay in the market.
Such pricing plays an important role in the overall accounting of large corporations. Because companies can also unlawfully manipulate transfer pricing in order to avoid taxes by shifting profits to lower-tax jurisdictions, the IRS plays a key part in policing the honest use of transfer pricing.
For example, GlaxoSmithKline paid over $3 billion in 2006 to resolve IRS allegations of transfer pricing fraud.
Whistleblowers with information regarding companies engaged in transfer pricing fraud are encouraged to report to the IRS Whistleblower Office. If one reports such fraud with the help of qualified IRS whistleblower attorneys, the whistleblower may remain anonymous.
Hagens Berman represents several whistleblower actions under the IRS Whistleblower Program, and marshals its significant nationwide resources and expertise in financial fraud matters, including attorneys who are also accountants and licensed forensic accountants, to best present whistleblower matters to the IRS.