Transfer Pricing

Intercompany pricing documentation and compliance for international structures

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Why Choose This

When your business operates across borders with related entities, every intercompany transaction โ€” from management fees and royalties to cost-sharing and inventory transfers โ€” must be priced at arm's length to satisfy the IRS and foreign tax authorities. WeSaveTax's transfer pricing team prepares robust documentation, conducts benchmarking studies, drafts intercompany agreements, and files all required forms to keep your international structure compliant and audit-proof.

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Policy Documentation

We prepare comprehensive transfer pricing documentation that meets IRS Section 6662(e) penalty protection standards, covering your intercompany transactions, pricing methodology, economic analysis, and supporting data.

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Arm's Length Analysis

Our economists conduct benchmarking studies using comparable company data, financial databases, and appropriate transfer pricing methods (CUP, TNMM, CPM, profit split) to demonstrate that your intercompany prices are at arm's length.

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Form 5471/5472

We prepare and file Form 5471 (for US shareholders of foreign corporations) and Form 5472 (for foreign-owned US corporations) reporting all reportable transactions with related parties โ€” avoiding penalties of $10,000+ per form for non-compliance.

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BEPS Compliance

We ensure your transfer pricing policies align with OECD BEPS (Base Erosion and Profit Shifting) guidelines, including master file, local file, and country-by-country reporting requirements for multinational groups.

How it works

How It Works

From first consultation to final delivery โ€” fully managed by qualified Tax Professionals.

Step 01 โ€” Assess Intercompany Transactions

Map all related-party transactions across entities

We conduct a thorough review of your corporate structure and identify all intercompany transactions โ€” service fees, royalties, cost-sharing payments, inventory sales, loans, and guarantees. Each transaction is characterised by type, direction, and value.

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Feature Deep Dive

Everything you need for seamless compliance

Transfer Pricing Documentation

We prepare contemporaneous transfer pricing documentation that satisfies IRS Section 482 regulations and provides penalty protection under Section 6662(e). Our reports include functional analysis, industry overview, method selection, economic analysis, and conclusions.

TAX SERVICE REPORTReviewed & Certified by Tax Expert

Arm's Length Benchmarking

Using financial databases such as S&P Capital IQ and Bureau van Dijk, we identify comparable uncontrolled transactions and companies to establish arm's length ranges for your intercompany prices, fees, royalties, and interest rates.

Tax Savings Analysisโ†‘ 34% saved

Intercompany Agreements

We draft and review intercompany service agreements, licensing agreements, cost-sharing arrangements, and loan agreements that align with your transfer pricing policy and reflect the economic substance of each transaction.

Compliance Calendar โ€” FY 2025-2615 JunAdvance Tax Q1Due15 SepAdvance Tax Q2Due31 OctIncome Tax AuditDue20 OctGSTR-3BDue11 NovGSTR-1Due31 DecROC FilingDue31 MarYear EndDue

Country-by-Country Reporting

For multinational enterprise groups meeting the revenue threshold, we prepare Form 8975 (Country-by-Country Report) disclosing revenue, profit, tax, and employees by jurisdiction โ€” satisfying OECD BEPS Action 13 requirements.

100% Compliantโœ“ Zero Penaltiesโœ“ On-Time Filingโœ“ Expert Verifiedโœ“ 100% Compliant

WeSaveTax vs Others

See how we compare on what matters most

FeatureWeSaveTaxFreelancerDIY / Self
TP Documentation
Benchmarking StudyExtra Cost
Form 5471/5472 FilingRisky
Agreement DraftingExtra Cost
APA AdvisoryVaries
PricingFrom $2,499$5,000+$3,500+

What Our Customers Say

Join thousands of happy taxpayers across India

โ€œOur US subsidiary was paying management fees to our parent in Germany with no documentation. WeSaveTax prepared a full benchmarking study, drafted the intercompany agreement, and filed the Form 5472. We are now fully protected for audit.โ€

Richard Hoffman

San Francisco, CA

โ€œWe have a US-India structure with software development services flowing between entities. WeSaveTax documented the entire arrangement, benchmarked our service fees, and filed both Form 5471 and the Indian TP report. Seamless cross-border expertise.โ€

Anita Sharma

Jersey City, NJ

โ€œThe IRS opened a transfer pricing examination on our intercompany royalty payments. WeSaveTax prepared a robust defence with comparable licensing data and the case was closed with no adjustment. Their documentation saved us from a significant assessment.โ€

Mark Stevens

Austin, TX

Frequently Asked Questions

Quick answers to common questions

Common triggers include large intercompany transactions relative to total revenue, significant payments to low-tax jurisdictions, inconsistent profit margins compared to industry benchmarks, missing or incomplete Form 5471/5472 filings, and sudden shifts in profitability after restructuring. The IRS has dedicated transfer pricing examination teams and uses data analytics to identify audit targets.

The arm's length principle requires that intercompany transactions between related entities be priced as if the parties were independent, unrelated companies dealing at arm's length. This means the price, terms, and conditions of intercompany transactions should be consistent with what would be agreed between unrelated parties in comparable circumstances. The IRS uses this standard under Section 482 to evaluate and adjust transfer prices.

If your US entity engages in transactions with related foreign entities โ€” including service fees, royalties, inventory sales, loans, or cost-sharing arrangements โ€” you should maintain contemporaneous transfer pricing documentation. While there is no strict dollar threshold for documentation, having proper documentation provides penalty protection under Section 6662(e) and demonstrates good faith compliance during an IRS examination.

Form 5471 (Information Return of US Persons with Respect to Certain Foreign Corporations) must be filed by US shareholders who own 10% or more of a foreign corporation, US persons who are officers or directors of a foreign corporation with US shareholders, and US persons who acquire or dispose of stock in a foreign corporation. The penalty for failing to file is $10,000 per form per year, and it can also trigger extended statute of limitations on your entire tax return.

Transfer pricing documentation should be updated annually to reflect current-year financial results, changes in business operations, new intercompany transactions, and updated benchmarking data. Even if your business model has not changed, the economic analysis must be refreshed with current-year comparable company data. We recommend a full benchmarking study every three years with annual updates in the interim.

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