Transfer pricing consulting begins with understanding the transactions between related companies. Before choosing a method or commissioning a report, build a reliable account of who provides what, who benefits and how the charges reach the books. This preparation is useful when discussing transfer pricing support for US subsidiaries.
Separate transaction types before reviewing prices
List related-party purchases and sales, management services, financing, intellectual-property arrangements and other material dealings. Identify the entities, countries, periods and currencies involved. An annual total labelled “management fee” is less informative than an explanation of the work and charging process.
The IRS describes the arm’s-length principle for related-party pricing. This overview establishes the concept; it does not prescribe the right method or price for your arrangement.
Prepare a transaction evidence file
- A group ownership chart and descriptions of each entity’s activities.
- Agreements, invoices and the calculations supporting charges.
- Financial statements and transaction-level accounting records.
- Descriptions of the people, assets and business risks involved.
- Existing studies, policies and correspondence explaining earlier decisions.
For each transaction, write down how it actually operates. Who approves the work? Which company employs the people doing it? What information supports the allocation? A document should help the reviewer understand the business, rather than substitute for that understanding.
Connect the explanation to the numbers
Reconcile the amounts in the proposed documentation to invoices and the ledger. If a year-end adjustment exists, retain the calculation and approval history. Explain changes in the arrangement or business conditions instead of silently carrying forward an old description.
The IRS documentation FAQs emphasize explaining how the facts and analysis support the pricing. Ask your adviser which documentation requirements and timing apply to your specific situation.
Frequently asked questions
Is an intercompany agreement the same as a transfer pricing study?
No. The agreement describes the arrangement; the pricing analysis evaluates the economic treatment. Accounting evidence helps show whether the arrangement was followed. Discuss each deliverable separately.
Can we reuse last year’s report?
Have the adviser review changes in transactions, functions, financial results and relevant requirements. Reusing a file without checking the facts can leave the explanation out of step with operations.
Will documentation guarantee acceptance by a tax authority?
No. Ask what the analysis supports, what assumptions remain and what limitations are stated. Avoid treating a report as a universal protection against examination or adjustment.
Discuss a defined scope
Explore transfer pricing services and intercompany agreement support. Contact Alfa Plus CPA with a description of the transactions and periods involved.
General information; the appropriate work depends on your circumstances. Official references checked October 21, 2026.