Tax Services

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

Entity Mapping

We map every intercompany relationship, transaction flow, and functional contribution across your entire corporate structure.

Functional Analysis

Detailed assessment of functions performed, assets employed, and risks assumed by each related entity in the value chain.

Benchmarking

Rigorous comparable analysis using industry databases to establish defensible arm's-length price ranges for every transaction type.

Documentation

Production of comprehensive, contemporaneous transfer pricing reports that satisfy both domestic and international filing requirements.

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.

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Who needs transfer pricing documentation?

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.

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 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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