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A major European manufacturing conglomerate was undergoing an audit of its transfer pricing policies by the IRS.
Leveraging its international resource base, NERA provided assistance to the taxpayer's legal counsel by documenting and supporting the arm's length nature of the taxpayer's transfer pricing policies. Upon resolution of the audit, NERA continued to assist the client with global documentation studies, thus minimizing future audit risk and transfer pricing penalty exposure.
NERA combined fact-based analysis and innovative financial modeling to enable the client to reach a favorable settlement with the tax authorities.