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Transfer Pricing Services
Expert transfer pricing documentation and strategy to keep your intercompany transactions compliant and audit-proof under Section 482.
Arm's-Length Compliance for Global Operations
When goods, services, or intangible property move between related entities across borders, the IRS demands that every transaction be priced at arm's length, the same price unrelated parties would negotiate in the open market. Failure to document and defend these prices exposes your business to devastating penalties, double taxation, and prolonged audit cycles.
SMAART Company delivers rigorous transfer pricing documentation, benchmarking studies, and intercompany agreement structuring that satisfies both US and international regulatory requirements. Our team combines deep Section 482 expertise with practical business understanding to design pricing policies that are defensible, efficient, and strategically aligned with your global operations.
Whether you are a multinational corporation with complex supply chains or a growing eCommerce brand with offshore fulfillment teams, we build the transfer pricing framework that protects your bottom line.
Core Directives
Global Compliance
Audit-Proof Defense
Tax-Efficient Structuring
Operational Milestones
01
Entity Mapping
We map every intercompany relationship, transaction flow, and functional contribution across your entire corporate structure.
02
Functional Analysis
Detailed assessment of functions performed, assets employed, and risks assumed by each related entity in the value chain.
03
Benchmarking
Rigorous comparable analysis using industry databases to establish defensible arm's-length price ranges for every transaction type.
04
Documentation
Production of comprehensive, contemporaneous transfer pricing reports that satisfy both domestic and international filing requirements.
05
Ongoing Strategy
Annual monitoring, policy updates, and proactive adjustments as your business structure or tax regulations evolve.
Included Services & Outcomes
Transfer Pricing Documentation & Benchmarking Studies
Functional & Risk Analysis Reports
Section 482 Compliance Reviews
Intercompany Agreement Drafting & Review
Transfer Pricing Policy Design (Cost-Plus, Resale-Minus, Royalty Rates)
Risk Assessment & Audit Readiness Evaluations
Ongoing Monitoring & Annual Updates
Advance Pricing Agreement (APA) Support
Cross-Border Transactions Under a Microscope
The IRS is aggressively auditing intercompany pricing. Proper documentation is not optional, it is your first and strongest line of defense.
FAQ
Questions &
Answers
Get answers to the most common questions about our transfer pricing services services.
Any US business that transacts with foreign affiliates, subsidiaries, or related entities across borders. This includes multinational corporations, eCommerce companies with offshore teams, import-export businesses, and real estate firms with shared international management.
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.
At minimum, annually. Any material change in business operations, entity structure, or regulatory environment should trigger an immediate review and update of your documentation.
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.
Most studies deliver in 6 to 10 weeks, functional analysis in weeks one and two, benchmarking in weeks three through six, and documentation drafting through closeout. Expedited timelines are available when audit notices or acquisition closings demand it.
Protect Your International Structure
Schedule a confidential transfer pricing review with our international tax specialists to ensure every intercompany transaction is defensible and optimized.
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