Transfer pricing services
What is transfer pricing?
Transfer pricing is the framework that governs the pricing of transactions between related entities, including goods, services, intellectual property and financing arrangements. Potentially applicable to both international and domestic operations, transfer pricing affects how income and expenses are allocated among entities and taxing jurisdictions, making it a key area of tax compliance, planning and controversy.
Successful transfer pricing balances compliance and commercial realities. Organizations must establish, document and support intercompany pricing policies that align with the arm's-length principle, applicable tax regulations, and the Organisation for Economic Co-operation and Development (OECD) guidance while remaining operationally effective and defensible under tax authority scrutiny.
How transfer pricing works
Determining arm's-length intercompany prices requires an understanding of how value is created among related entities. This analysis considers the functions performed, risks assumed and assets employed by each entity, as well as the economic terms of the intercompany transaction.
The objective is to establish pricing consistent with the terms that independent parties would agree to under comparable circumstances. This arm's-length standard is the foundation on which tax authorities worldwide evaluate whether intercompany pricing yields supportable, market-based outcomes.
How RSM supports transfer pricing compliance, planning and strategy
RSM helps organizations develop and execute transfer pricing strategies that support broader business, tax and operational objectives across the full transfer pricing lifecycle. From policy design and value chain analysis to implementation, documentation and controversy support, our teams work with clients to build practical, defensible transfer pricing frameworks aligned with Section 482 regulations, OECD guidance and the realities of how the business operates.
Rather than approaching transfer pricing solely as a compliance exercise, RSM advises organizations on how intercompany pricing can adapt to growth, transformation and changing tax authority expectations. We help clients assess the transfer pricing implications of entering new markets, restructuring supply chains, integrating acquisitions and responding to evolving business models, while also preparing documentation, benchmark studies and economic analyses that support compliance with U.S. and international requirements.
As global scrutiny of intercompany transactions continues to increase, organizations need transfer pricing policies that are not only supportable, but also operationally sustainable and responsive to risk. RSM helps clients align transfer pricing outcomes with documented policies, business functions and strategic priorities, while preparing for tax authority review and managing controversy with confidence.
Why partner with RSM for transfer pricing services
Manage risk proactively and navigate controversy strategically
Identify transfer pricing risks early, assess potential exposures and develop practical strategies to strengthen audit readiness, manage disputes and address year-end adjustments in a thoughtful, business-aligned manner
Prepare for and respond to domestic and foreign audits
Support interactions with tax authorities through well-developed documentation, economic analysis, audit defense and response strategies designed to help organizations prepare for scrutiny and resolve issues efficiently
Evaluate the transfer pricing impact of business change
Assess the transfer pricing implications of market expansion, restructurings, acquisitions, supply chain transformation and operating model changes so intercompany pricing remains aligned with evolving business realities
Monitor results and sustain policy alignment
Track transfer pricing outcomes, evaluate whether results remain consistent with established policies and implement adjustments as needed to support compliance, maintain operational alignment and reduce controversy risk
Transfer pricing services and solutions
RSM helps organizations design, implement and sustain transfer pricing approaches that align with business operations, regulatory expectations and broader tax strategy.
We build operational transfer pricing processes that translate policy into execution across finance, systems, data and governance to help maintain alignment and improve sustainability.
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Software company saves millions via a transfer pricing study
The investors were pleased with the $2 million in tax savings and the integrated global approach exhibited by the team and engaged RSM to handle their tax compliance projects at another venture investment.
Industrial products company tackles a major transfer pricing issue with the Dutch taxing authority
Lesson learned: A proactive approach to presenting a company’s transfer pricing structure in a clear, positive manner can often prevent extensive superfluous requests for data and satisfy the audit requirements of a questioning taxing authority.