Tax Services
Transfer Pricing
Intercompany transaction structuring and documentation
Arm's-Length Compliance for Global Operations
When goods, services, or intangibles move between related entities across borders, the IRS demands every transaction be priced at arm's length. Failure to document and defend these prices exposes you to penalties and double taxation.
Defensible documentation and benchmarking that satisfies IRS Section 482 and OECD requirements at once.
Core Directives
- Global Compliance
- Audit-Proof Defense
- Tax-Efficient Structuring
Ready when you are
Get startedOperational Milestones
Map & Analyze
We map every intercompany relationship and transaction flow, then assess the functions, assets, and risks of each related entity.
Benchmark
We run rigorous comparable analysis using industry databases to establish defensible arm's-length price ranges for each transaction type.
Document & Maintain
We produce contemporaneous reports satisfying domestic and international requirements, with annual monitoring and policy updates.
Included Services & Outcomes
Unsupported Pricing Invites Adjustments
The IRS is aggressively auditing intercompany pricing. Proper documentation is not optional, it is your first and strongest line of defense.
Questions
Transfer Pricing FAQ
Who needs transfer pricing documentation?
Any US business that transacts with foreign affiliates, subsidiaries, or related entities across borders, including multinationals, eCommerce companies with offshore teams, import-export businesses, and real estate firms with shared international management.
What happens if my transfer pricing is not compliant?
The IRS can reallocate income between related entities under Section 482, resulting in double taxation, substantial penalties (up to 40% of the underpayment), and interest charges. Proper documentation is your primary defense.
How often should transfer pricing studies be updated?
At minimum, annually. Any material change in business operations, entity structure, or regulatory environment should trigger an immediate review and update of your documentation.
What is the arm's-length standard?
It requires that prices charged between related parties mirror what independent, unrelated parties would negotiate under comparable circumstances. The IRS uses several approved methods, comparable uncontrolled price, cost-plus, resale price, and profit-split, to test compliance.
How long does a transfer pricing study take?
Most studies deliver in 6 to 10 weeks: functional analysis in weeks one and two, benchmarking in weeks three through six, and documentation through closeout. Expedited timelines are available when audit notices or closings demand it.
Put SMAART Tax on your transfer pricing
Book a free consultation. We'll review your situation, quote a fixed fee, and show you exactly what we'd do differently.