Right-sized transfer pricing — method, agreements, and a real safe harbor.
Most foreign-owned U.S. businesses with $1M–$25M in revenue can't justify a $25,000 benchmarking study — but they still need their intercompany method documented and their agreements properly papered. We build that, and where routine services are involved we add the Services Cost Method safe harbor for genuine §6662(e) protection. When a royalty rate or product margin truly needs benchmarking, we say so and coordinate an economist.
Se habla Español · Se fala Português. Fixed-fee engagements — you always know the price before work begins.
Between 'nothing' and 'overkill,' there's a smart middle
Skip documentation and you're exposed to penalties and income reallocation. Buy the full study you don't need and you've wasted five figures. We built the option in between.
Undocumented intercompany pricing is a penalty magnet
Management fees, cost recharges, IP licenses, and loans with your parent must be supported. Without proper documentation — and, for the right flows, a safe harbor or benchmarking — the IRS can reallocate income and apply §6662(e) penalties.
Full benchmarking studies cost $25,000+
A comparable-company economic study makes sense for large multinationals. For a $3M-revenue subsidiary with one or two intercompany flows, it's wildly disproportionate.
Generic agreements won't save you
A template intercompany agreement with no functional analysis or method memo behind it doesn't meet the documentation standard — and won't hold up when examined.
For foreign-owned U.S. businesses with a handful of intercompany flows
If your related-party transactions are real but contained, this is the right-sized solution — not too little, not a five-figure overspend.
Tell us about your situation- A foreign-owned U.S. subsidiary with $1M–$25M in revenue
- Charging or paying a parent for management, services, or cost recharges
- Running management fees, cost recharges, or intercompany loans within the group
- Wanting your intercompany method documented and agreements properly papered
- Running routine back-office services that may qualify for the cost safe harbor
- Annual intercompany volume comfortably under $10 million
Intercompany method & agreements, scoped to your transactions
Priced by how many types of intercompany transactions you run. This papers your method and agreements; for accuracy-penalty protection, pair it with the Services Cost Method safe harbor (routine services) or a coordinated full study — both explained below. Year 2 onward is a lighter update.
Single Transaction
- Functional analysis (functions, assets, risks)
- Method-selection memo under IRC §482
- Industry & business overview
- Customized intercompany agreement
- Year-end true-up worksheet
- Documents your method — not a standalone penalty shield
2–3 Transactions
- Everything in Single, covering 2–3 transaction types
- Multiple customized intercompany agreements
- Method analysis for each transaction type
- Risk mapping across the group
- Year-end true-up worksheet
- Annual refresh of factual sections in later years
4–5 Transactions
- Everything above, covering 4–5 transaction types
- Full suite of intercompany agreements
- Method analysis across all flows
- Risk mapping and coordination with your filings
- Year-end true-up worksheet
- Annual refresh in later years
1) Services Cost Method (SCM) safe harbor — from $6,000. If your intercompany charges are routine back-office services (IT, payroll, accounting, HR, administrative support), the SCM lets you price them at cost and gives real penalty protection — no benchmarking database required. We build the cost pools, allocation keys, and business-judgment-rule memo. It does not cover goods, royalties or IP licenses, cost-sharing, or executive / core management services.
2) Coordinated full §482 study — referral + $2,500. When the contested number is a royalty rate, a product margin, or any non-routine flow — or intercompany volume tops ~$10M, or the IRS opens an exam — real protection needs comparables and economic analysis. We scope and quarterback the engagement and a transfer-pricing economist produces the study.
The method-and-agreements tiers above document your transfer-pricing method and paper your intercompany agreements under IRC §482. By themselves, without comparables and economic analysis, they are NOT a complete accuracy-related penalty defense under Treas. Reg. §1.6662-6 — that defense requires either the Services Cost Method (for qualifying routine services) or a full benchmarking study. We tell you in writing which path your facts call for. Fees are starting points confirmed in your engagement letter.
Not ready for a full engagement?
Start with a 60-minute Orientation Session — your realistic paths, your exact filing list and deadlines, and a one-page written summary. $750 flat, credited in full toward any engagement within 60 days.
Documentation that's proportionate — and honest about its limits
We tell you exactly what this protects you against and exactly when you'd need more. No overselling, no false comfort.
From first call to filed & handled
No surprises, no scope creep, no jargon. Just a clear path and a fixed fee.
Free strategy session
We map your intercompany flows and confirm light documentation fits.
Engagement letter
A fixed fee and clear scope — including what's excluded — in writing.
Build the file
Functional analysis, method memo, agreements, and true-up worksheet.
Stay current
A lighter annual update keeps your documentation contemporaneous.
Transfer pricing documentation, answered
What exactly do I get — and what's excluded?
The method-and-agreements tiers give you a functional analysis, a method-selection memo under IRC §482, an industry overview, customized intercompany agreements, and a year-end true-up worksheet. That documents and papers your pricing. What those tiers do not include is the comparables and economic analysis that a full accuracy-penalty defense requires — for that you add the Services Cost Method safe harbor (routine services) or a coordinated full study. We're explicit about which you need.
Will this protect me from §6662(e) penalties?
Honestly, it depends on the flow. For routine back-office services, the Services Cost Method safe harbor gives real protection by letting you price at cost — and we build that. For goods, royalties, IP, or other non-routine flows, genuine penalty protection requires comparables and economic analysis (a benchmarking study), which we coordinate with an economist. The method-and-agreements documentation alone supports the reasonableness of your method but is not, by itself, a complete penalty defense. We put which path applies to you in writing.
What is the Services Cost Method and why does it matter?
It's a safe harbor under the §482 regulations and Rev. Proc. 2007-13 that lets certain routine, low-margin support services (IT, payroll, accounting, HR, administrative functions) be charged between related parties at cost — with genuine penalty protection and no benchmarking database needed. It's the most cost-effective real protection available for the right facts. It does not apply to product sales, royalties/IP, cost-sharing, or high-value management services.
Why is this cheaper than the big firms quote?
Because we scope to what a $1M–$25M business actually needs: documented method, proper agreements, and the SCM safe harbor where it fits — reusing a refined agreement library — and we coordinate (rather than mark up) a full economic study only when your facts genuinely require one.
What about an intercompany royalty or IP license?
That's the one flow we keep out of the method-and-agreements tiers. An inbound royalty is a deductible payment to a related foreign party, and the number the IRS contests is the rate — which only a royalty-rate benchmarking study can defend. We prepare the agreement and surrounding analysis and coordinate the rate study with a transfer-pricing economist, rather than imply a fixed light engagement protects it.
When would I genuinely need the full study instead?
When the contested number is a royalty rate or product margin, you have six or more transaction types, an intangible buy-in or cost-sharing arrangement, intercompany volume above roughly $10M, or an active examination. We flag any of these early and bring in a transfer-pricing economist rather than let you rely on documentation that wouldn't hold.
Do you only work with companies in Texas?
No. Federal international filings — Forms 5472, 5471, 1120-F, FIRPTA withholding — have no state boundary, and we serve foreign-owned companies in all 50 states. We're based in Houston, one of America's largest international business hubs, and we prepare state filings for whichever state your entity is in (Texas franchise reports included for Texas entities).
Get right-sized transfer pricing protection
Book a free strategy session. We'll map your intercompany flows, confirm whether light documentation fits, and quote a fixed fee.