Services
Management, technical, administrative, and shared services
U.S. transfer pricing services
Transfer pricing services.
Set, support, and apply arm's-length pricing for transactions between companies under common control.
Figures maps the flows, selects and benchmarks the method, prepares the study and documentation, and carries the policy into invoices, allocations, ledger entries, monitoring, and year-end true-ups. For growth-stage and lower-middle-market groups with U.S. controlled transactions.
- Section 482
- The U.S. controlled-transaction standard
- 30 days
- Documentation response window under applicable Section 6662 rules
- Policy → books
- Implementation, monitoring, and true-ups
Your method, documentation, actual conduct, and books should support the same position.
Section 482 applicability
Does Section 482 apply to your business?
Section 482 applies to transactions between taxpayers under common control. It can cover domestic and cross-border arrangements. The core question is whether the result reflects what uncontrolled parties would have reached under comparable circumstances.
Goods
Manufacturing, distribution, inventory, and supply-chain flows
Financing
Intercompany loans, guarantees, cash pools, and advances
Intangibles
Royalties, licenses, software, brands, know-how, and IP
Allocations
Shared costs, central functions, and group overhead
Changes
Restructurings, asset transfers, and shifts in functions or risk
Where Section 482 risk builds
The position can fail before the IRS ever asks.
Transfer-pricing risk is rarely one missing document. It builds when the method does not fit the facts, the financial data cannot be reproduced, the policy is not followed in the books, or the support is prepared too late.
Can you show why your method is the most reliable one?
Section 482 does not give one method automatic priority. The analysis needs to fit the transaction, the available comparables, and the quality of the data.
Does the study tie back to the actual books?
Segmented tested-party results, cost bases, allocations, and adjustments should reconcile to the financial data behind the tax return.
Do the invoices and entries follow the written policy?
A report can describe one pricing model while the business invoices, allocates, or records something different. That gap weakens the position.
Would the documentation be ready if the IRS asked today?
When Section 6662 penalty-protection rules apply, documentation generally must already exist when the return is filed and be provided within 30 days of a request.
U.S. transfer pricing services
From transaction map to year-end true-up.
Figures covers the core transfer-pricing lifecycle. The work starts with the controlled transaction, supports the method with economic analysis, and carries the position into the finance operation.
Transaction mapping and risk review
See every controlled flow before you choose a method.
We map the entities, transaction types, agreements, functions, assets, risks, and financial data that shape the U.S. transfer-pricing position.
- Inbound and outbound transaction map
- Related-party flow inventory
- Documentation and data-gap review
Functional analysis and method selection
Set pricing around how the business actually creates value.
We analyze the functions performed, assets used, and risks assumed, then select and document the method that best fits the facts and available data.
- Functional and risk analysis
- Best-method assessment
- Intercompany pricing policy
Economic analysis and arm's-length ranges
Support the price with a reproducible comparison set.
We define the tested party, profit-level indicator, screening logic, and comparable set needed to support a defensible arm's-length result.
- Comparable-company or transaction search
- Financial screening and adjustments
- Arm's-length range analysis
Transfer-pricing study and Section 6662 support
Build the file before it becomes an IRS request.
We prepare a clear study that connects the controlled transactions, method, comparables, assumptions, financial data, and conclusions.
- Contemporaneous documentation support
- Method and comparability narrative
- Financial schedules and workpapers
Policy-to-ledger execution
Turn the study into the way the company actually operates.
We connect the policy to intercompany agreements, invoices, cost allocations, accounting entries, management reporting, and owner workflows.
- Invoice and allocation mechanics
- Ledger and reporting alignment
- Operating ownership and controls
Outcome testing and year-end true-ups
Find drift while there is still time to address it.
We compare actual entity results with the policy during the year, investigate variances, and help the finance and tax teams evaluate appropriate true-ups.
- Periodic margin testing
- Variance and data review
- Year-end true-up support
Methods and benchmarking
The best method depends on the facts and the data.
The regulations call for the method that provides the most reliable arm's-length measure under the circumstances. Comparability and data quality carry more weight than a preferred template.
Read the best-method rule in 26 CFR 1.482-1Scroll sideways to read the full methods table.
| Method | When it may fit |
|---|---|
| Comparable uncontrolled price | A comparable price exists for the same or a sufficiently similar transaction. |
| Resale price | A distributor buys from a related party and resells to independent customers. |
| Cost plus | A supplier or service provider earns a supportable markup on an appropriate cost base. |
| Comparable profits method | Comparable companies can support a tested party's profit-level indicator. |
| Profit split | Both sides make unique and valuable contributions or the activity is highly integrated. |
| Services cost method | Eligible low-margin covered services meet the specific regulatory conditions. |
This table is a general orientation. Method selection depends on the controlled transaction, the functions and risks, available comparables, contractual terms, and reliable financial data.
Documentation readiness
A report does not create automatic penalty protection.
The IRS evaluates whether the method selection, application, inputs, and documentation are adequate and reasonable. Figures builds the support around the actual transaction and financial data, not a generic report shell.
IRS transfer-pricing documentation FAQsPrepared on time
Documentation generally must exist when the return is filed when the applicable Section 6662 rules are being relied on.
Reasoned method
The file should explain why the chosen method and its application provide the most reliable arm's-length measure.
Reliable data
The analysis should document the data, assumptions, searches, adjustments, and financial tie-outs supporting the result.
Ready to provide
The documentation must be provided within 30 days of an IRS request during an examination.
How we work
Set the position. Put it into practice. Keep it current.
Map
Map the controlled transactions
We identify the entities, flows, agreements, people, functions, risks, and financial data that drive the position.
A complete transaction and data map
Support
Set and document the method
We select the method, complete the economic analysis, establish the range, and prepare the supporting study and workpapers.
A reasoned and documented arm's-length position
Operate
Implement and monitor the policy
We connect the position to invoices and accounting, test results during the year, and evaluate true-ups when facts or outcomes change.
A policy that stays aligned with the books
U.S. transfer pricing questions
Section 482, methods, and documentation, answered.
What is transfer pricing under Section 482?
Transfer pricing is the pricing of transactions between companies under common control. Section 482 authorizes the IRS to adjust income, deductions, credits, or allowances when needed to prevent tax avoidance or clearly reflect income. The regulations generally apply the arm's-length standard, which asks what uncontrolled parties would have agreed under comparable circumstances.
Does Section 482 apply only to cross-border transactions?
No. Section 482 can apply to transactions between controlled taxpayers whether the entities are domestic or cross-border. Cross-border arrangements receive particular attention because pricing affects how income and deductions are divided between tax jurisdictions. The exact analysis depends on the entities, transaction, facts, and applicable rules.
Does every U.S. company need a transfer-pricing study?
There is no single rule that requires every U.S. company with a controlled transaction to prepare the same report. The transaction still needs an arm's-length result. When the Section 6662 penalty rules and thresholds are relevant, timely and adequate documentation can be important to support the position and seek penalty protection.
What is contemporaneous Section 6662 documentation?
It is documentation prepared by the required time, generally when the tax return is filed, that explains the controlled transactions, the method selected, why that method was reasonable, how it was applied, the data used, and the resulting arm's-length analysis. A report alone is not enough if the method, inputs, or application are unreasonable.
How quickly must transfer-pricing documentation be provided to the IRS?
The IRS documentation FAQs state that documentation used for the applicable Section 6662 rules must be provided within 30 days of an IRS request during an examination. That deadline is one reason to prepare and maintain the support before a request arrives rather than reconstructing it after the fact.
Which U.S. transfer-pricing method should a company use?
The best method is the one that provides the most reliable measure of an arm's-length result under the facts and circumstances. The analysis considers comparability, the quality of the data and assumptions, and how reliably the method can be applied. No method automatically wins for every transaction.
What does a transfer-pricing benchmarking study support?
A benchmarking study compares the controlled result with data from sufficiently comparable uncontrolled companies or transactions. It documents the search strategy, screening criteria, adjustments, tested party, financial indicator, and resulting range used to support the intercompany price or margin.
What is operational transfer pricing?
Operational transfer pricing is the work of turning a written policy into repeatable business processes. It covers agreements, invoices, cost allocations, accounting entries, entity-level reporting, monitoring, and true-ups so the actual financial results follow the position described in the transfer-pricing study.
What happens if actual results fall outside the policy range?
The company should first understand why the result moved. Changes in functions, risks, transaction volumes, cost bases, market conditions, or accounting data can matter. The finance and tax teams can then assess whether the policy, calculation, documentation, or a year-end adjustment should be updated before filing.
Talk to an Advisor
Put your transfer-pricing policy into practice.
Tell us how your entities transact and what support already exists. We'll help you map the position, benchmark and document it, and carry it into the books and year-end process.
Controlled transactions, functions, and financial data mapped
Best-method analysis and benchmarking documented
Study, agreements, and actual conduct aligned
Invoice logic, allocations, and accounting treatment connected
Results monitored and true-ups evaluated before year-end
Talk to our transfer-pricing team
Tell us what your entities exchange and where you need support.