What's Included:
 
Initial Consultation & Scope Definition:
An in-depth session to understand your business model and identify specific intercompany transactions requiring transfer pricing analysis.
 
Functional Analysis Interview (FAR Analysis):
A structured process to gather critical information about the functions, assets, and risks associated with your U.S. entity and foreign related parties.
 
Arm's Length Principle Application & Method Selection:
Identification and application of the most appropriate transfer pricing method in accordance with U.S. Treasury Regulations (e.g., CUP, RPM, Cost Plus, TNMM) to ensure fair pricing.
 
Limited Benchmarking & Economic Analysis:
A review of publicly available data or industry comparables to support the arm's length nature of your pricing for simpler cases.
 
Note: This package excludes extensive, customized economic benchmarking studies involving complex financial modeling.
 
Transfer Pricing Documentation Memorandum:
Preparation of a concise memorandum summarizing our analysis, chosen method, and conclusions, providing crucial contemporaneous documentation for IRS compliance.
 
Risk Identification & General Recommendations:
Highlighting potential transfer pricing risks and offering general strategies for mitigation and ongoing compliance.
 
Key Benefits:
IRS Compliance: Helps meet basic IRS Section 482 documentation requirements.
Penalty Avoidance: Reduces the risk of substantial penalties for non-compliance.
Clarity: Provides a clear understanding of your intercompany pricing structure.
Expert Support: Guidance from experienced tax professionals.