US Transfer Pricing Consultants

Transfer pricing powered by iVC

700 projects completed in 5 years

US Transfer Pricing Strategy

Transfer pricing strategy starts with understanding how your business actually creates value. We design structures and agreements that align commercial reality with US tax expectations. Our work focuses on getting the fundamentals right so your US operations run with clarity, confidence, and long-term certainty. No templates, no guesswork, just practical strategy.

US Transfer Pricing Policy Design & Implementation

We build pricing policies that fit how you actually operate, not generic frameworks. Tailored to US rules and OECD standards, our approach strengthens governance, ensures consistent pricing, and creates positions that hold up under scrutiny from tax authorities.

US Value Chain Analysis & Substance Alignment

We map where value actually gets created in your business, who does the work, who takes the risk, who owns the assets. This analysis strengthens compliance, builds transparency, and reduces US tax exposure by showing your transfer pricing documentation reflects genuine economic reality, not theory on paper.

Your intercompany agreements need to tell a story that makes sense. We draft agreements that accurately reflect your functions, risks, and assets so when tax authorities ask questions, the answers are already there. This strengthens audit readiness and ensures consistent pricing across your global operations.

Intercompany Agreement Review & Drafting

Transfer Pricing and Beyond! If you are looking for a quality service and advice that works in practice, iVC Consulting should be your choice. Extensive professional knowledge, knowing its client, practical approach - that's what makes a difference.

Agnė Petkevičiūtė
Director of Tax
Vinted

★★★★★

Supported Vinted's shift from ($118m) in 2022 to $17m in 2023

US Transfer Pricing Compliance

Compliance is not just about ticking boxes, it is about being ready when tax authorities come knocking. We handle documentation, benchmarking, and risk assessments that keep you safe. Get this right and you will sleep better knowing an audit will not derail your business or drain your resources.

Benchmarking & Economic Analysis for Compliance

We identify where US tax authorities are likely to look and whether you are ready. Our assessment uncovers governance gaps, documentation weaknesses, and audit risks. Then we give you actionable insights to strengthen your position and build a framework that holds up when tested.

US Transfer Pricing Risk Assessment & Compliance Reviews

We prepare the transfer pricing documentation US authorities expect to see. Master File and Local File, fully aligned and defensible. The result: compliant, consistent documentation you can rely on with confidence in any enquiry.

US Master File, Local File & Concurrent Documentation

We find comparable companies that actually look like yours, not just database matches. This evidence helps you defend your transfer pricing, strengthens your position, and keeps you compliant with what US authorities expect from your documentation and analysis.

US Operational Transfer Pricing

Transfer pricing is not just an annual exercise. We build processes and controls that keep your transfer pricing compliant month to month. Our tools enhance accuracy, streamline workflows, and reduce tax risk by making transfer pricing part of how you operate.

Operational Transfer Pricing for Lithuanian Businesses

Transfer pricing only works if it is executed properly in practice. We build the processes, controls, and dispute mechanisms that keep your pricing consistent and compliant day to day. The goal is transparency, accuracy, and the confidence that comes from knowing your transfer pricing works.

Audit Defence & Dispute Resolution

Tax audits are stressful. We have been through many. We provide strategic positioning, technical analysis, and direct engagement with tax authorities to resolve issues efficiently and protect you from double taxation and penalties that could impact your business.

We guide you through APA and MAP processes to secure long-term certainty and prevent double taxation. Our structured approach and coordination with tax authorities help you achieve sustainable, predictable pricing outcomes for your business.

Advance Pricing Agreements - APAs & MAP

Long-term Transfer Pricing Partner

Vinted

• Weekly calls for the last 5 years focused on transfer pricing, cross-border scaling, accounting and M&A integration

• 200+ projects delivered across multiple workflows and many stakeholders

• Coordination of work through a Project Management platform

• Four M&A integrations, two spin-offs

• Intercompany transaction calculation tool for accounting ease and financial oversight of the group entities

• Supported shift from 111m USD loss (2022) to 89m USD profit (2024)

Docplanner

• Monthly calls for last 4 years focused on international tax, financial audit support, finance, M&A, etc.

• 100+ projects delivered over four years

• Designed and maintained a streamlined global transfer pricing structure

• Intercompany transaction calculation tool for accounting ease and financial oversight of the group entities

Frequently asked questions

What is transfer pricing, and why does it matter for US businesses?

Transfer pricing governs the prices your US entity charges or pays to related companies for services, goods, IP, loans, royalties, management fees, or other intercompany transactions. The IRS expects these prices to reflect what independent parties would agree under comparable circumstances. If they do not, income can be reallocated, tax reassessed, interest charged, and penalties applied. It matters for any US business with domestic or cross-border related-party transactions.

What triggers a IRS transfer pricing audit?

IRS transfer pricing reviews are commonly triggered by cross-border related-party transactions, US entities reporting losses or unusually low margins, IP transfers, royalties, management fees, intercompany financing, cost-sharing arrangements, business restructurings, and inconsistent documentation. The IRS will focus on whether people, assets, risks, and profits are aligned. Weak or late documentation can quickly become a major audit problem.

Do I need transfer pricing documentation if I am a smaller business in the US?

Yes, if your US business has related-party transactions, you should be able to justify the pricing. The US rules are not only a large multinational issue. Documentation should explain the transaction, the parties involved, the method used, the comparables relied on, and why the result is arm’s length. Smaller businesses may prepare proportionate documentation, but it still needs to be credible before an IRS review starts.

What is an arm’s length price and how do I prove it in the US?

An arm’s length price is the price independent businesses would have agreed under comparable circumstances. In the US, this is proven through a clear functional analysis, appropriate transfer pricing method, reliable comparables, financial evidence, and consistent application of the policy. Weak comparables, unsupported management charges, or after-the-fact analysis increase the risk of an IRS adjustment.

What are the transfer pricing penalties in the US?

US transfer pricing penalties can apply where an IRS adjustment creates an underpayment of tax. In many transfer pricing cases, accuracy-related penalties may be 20% or 40% of the underpayment, depending on the size and nature of the adjustment. Contemporaneous documentation can help reduce penalty exposure, but only if it is prepared on time, reasonable, and provided to the IRS when requested.

Get in touch

US Transfer Pricing Updates and Changes 2026

From 2025 onwards, the pressure points are not limited to one reform. They now cut across international tax rates, simplified distribution pricing, IP transfer adjustments, APA capacity, tariffs and customs valuation, royalty disputes, and cost-sharing arrangements.