About Us
Armize Consulting is a U.S.-based firm specializing in preparing transfer pricing documentation in compliance with U.S. regulations.
We provide optimal arm’s length results that take into account each client’s specific business circumstances and align with the perspectives of both U.S. and foreign tax authorities.
We offer affordable, high-quality transfer pricing documentation by leveraging the founder’s 15+ years of experience in transfer pricing and
project management at a Big 4 firm. This experience includes implementing AI technologies, standardizing work tools, and introducing process improvements that enhanced efficiency.
New
Documentation
Update of Existing
Documentation
Optimizing an arm's length result
We specialize in preparing transfer pricing documentation
in compliance with U.S. transfer pricing regulations.
Pricing
$25,000
New Documentation
Full preparation of
documentation starting from
scratch
Update of Existing
Documentation
With New Benchmark
Full update of previously
prepared documentation,
including a new
benchmarking analysis with
updated comparables
$15,000
Update of Existing
Documentation
With Financial Data Refresh
Minor update of a previously
prepared documentation using
the same set of comparables,
with refreshed financial data and a recalculated arm's length range
$5,000
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The Comparable Profits Method (CPM) is used. Using of other transfer pricing methods requires prior consultation.
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Benchmark analysis is based on one set per documentation.
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Upon request,
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Additional benchmark sets are available for an extra fee of $XX per set.
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Additional financial data refreshes can also be provided for an extra fee of $XX per set.
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What is transfer pricing documentation?
Transfer pricing documentation is a collection of records and analyses demonstrating that controlled transactions between a U.S. entity and its foreign subsidiary are conducted in accordance with the arm’s length principle.
The required contents of transfer pricing documentation are specified in Treas. Reg. §1.6662-6(d)(2)(iii)(B) – Principal documents.
Business Overview
Controlled
Transactions
Organizational Structure
Comparables
Documentation Required Under §482
Economic Analysis
Economic Analysis
Selected Method
Relevant New Data
Alternative Method
General Index of Principal and Background Documents
The following is a sample outline of the transfer pricing documentation we typically prepare for our clients.
Transfer Pricing Documentation
1. Introduction and Executive Summary
2. Corporate Overview
・Overview of U.S. entity, and its foreign subsidiary
・Capital relationship structure
・Overview of Business
・Financial Results
・Overview of Products, Customers,
Suppliers, and other relevant business elements
3. Intercompany Transactions
・Overview of Transactions
・Transaction Flow Chart
・Transfer Pricing Policy
4. Industry Analysis
・Analysis of the Client's Industry
5. Functions and Risks Analysis
・Functions Performed
・Risks Owned
・Assets Utilized
6. Selection of Transfer Pricing Methods
・Best Method Rule
・Selection of the CPM as the Best
Method
・Evaluation of Alternative Methods
7. Economic Analysis
・Application of the CPM Method
・Selection of Profit Level Indicator
・Selection of Tested Party
・Selection of Years for Comparison
・Selection of Comparable Companies
✓ Search Strategy
✓ Database Search
✓ Quantitative Screening
✓ Qualitative Screening
✓ Adjustments to the Comparables
Companies Data
✓ Search Results
8. Conclusion
9. Appendices
・Organizational Structure
・Financial Statements
・Intercompany Agreements
・Search Matrix for Comparables
Companies
・Financial Data of the Selected
Comparables Companies
Business
Overview
Organizational
Structure
Documentation
Required Under §482
Alternative
Method
Selected
Method
General Index of
Principal and
Background Documents
Relevant
New Data
Economic
Analysis
Comparables
Controlled
Transactions
Transfer pricing documentation
1. Introduction and Executive Summary
2. Corporate Overview
・Overview of U.S. entity, and its
foreign subsidiary
・Capital relationship structure
・Overview of Business
・Financial Results
・Overview of Products, Customers,
Suppliers, and other relevant
business elements
3. Intercompany Transactions
・Overview of Transactions
・Transaction Flow Chart
・Transfer Pricing Policy
4. Industry Analysis
・Analysis of the Client's Industry
5. Functions and Risks Analysis
・Functions Performed
・Risks Owned
・Assets Utilized
6. Selection of Transfer Pricing Methods
・Best Method Rule
・Selection of the CPM as the Best
Method
・Evaluation of Alternative Methods
7. Economic Analysis
・Application of the CPM Method
・Selection of Profit Level Indicator
・Selection of Tested Party
・Selection of Years for Comparison
・Selection of Comparable Companies
✓ Search Strategy
✓ Database Search
✓ Quantitative Screening
✓ Qualitative Screening
✓ Adjustments to the Comparables
Companies Data
✓ Search Results
8. Conclusion
9. Appendices
・Organizational Structure
・Financial Statements
・Intercompany Agreements
・Search Matrix for Comparables
Companies
・Financial Data of the Selected
Comparables Companies
Why is transfer pricing documentation required?
Its primary purpose is to help avoid penalties. A taxpayer may avoid the 20% or 40% transfer pricing penalties if the following two conditions are met §1.6662-6(d)(2)(iii).
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Transfer pricing documentation is prepared and submitted in a timely manner
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The documentation includes a reasonable and reliable analysis
If either of these requirements is not met, the following transfer pricing penalties may apply.
Penalty
20%
Net adjustment is greater than the lesser of ＄5 million or 10% of gross receipts
Net adjustment
Price or value is 200% or more (or 50% or less) than correct amount
40%
Transactional
Price or value is 400% or more (or 25% or less) than correct amount
Net adjustment is greater than the lesser of ＄20 million or 20% of gross receipts
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In practice, because the Comparable Profits Method (CPM) is frequently applied to test the profitability of foreign subsidiaries, the net adjustment penalty is considered applicable in many cases.
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Whether the 20% or 40% Net Adjustment Penalty applies depends on the amount of the transfer pricing adjustment. The penalty is imposed at 20% or 40% of the additional tax liability arising from the adjustment.
Penalty
20%
Net adjustment
Net adjustment is greater than the lesser of ＄5 million or 10% of gross receipts
40%
Net adjustment is greater than the lesser of ＄20 million or 20% of gross receipts
Price or value is 400% or more (or 25% or less) than correct amount
40%
Price or value is 200% or more (or 50% or less) than correct amount
20%
Transactional
Penalty
When is deadline/statute of limitations?
<Deadline>
Preparation
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The documentation must be prepared by the due date for filing the company’s federal income tax return, which is 3 months and 15 days after the end of the tax year (e.g., April 15 for a calendar-year taxpayer).
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An automatic 6-month extension is available upon request (e.g., until October 15 for a calendar-year taxpayer).
Submission
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Within 30 days of a request from the IRS
<Statute of limitations>
Conditions
Normal Request
Years
Underreporting income by 25% or more
Treas. Reg.
3 years
False, Fraud, evade,
No return
6 years
Unlimited
In light of potential IRS audits, taxpayers are advised to retain transfer pricing documentation for at least 6 years.
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Within 30 days of a request from the IRS
Preparation
-
The documentation must be prepared by the due date for filing the company’s federal income tax return, which is 3 months and 15 days after the end of the tax year (e.g., April 15 for a calendar-year taxpayer).
-
An automatic 6-month extension is available upon request (e.g., until October 15 for a calendar-year taxpayer).
Submission
Normal Request
Conditions
Underreporting income by 25% or more
False, Fraud, evade,
No return
Unlimited
6 years
3 years
Years
§6501(e)(1)(A)
Treas. Reg.
Who should prepare transfer pricing documentation?
Transfer pricing documentation is often viewed as a form of insurance — not mandatory, but highly valuable in reducing penalties.
In practice, compliance is usually evaluated from a cost-benefit perspective. It is therefore reasonable to weigh the cost of preparing documentation against potential penalty exposure, considering factors such as the foreign subsidiary’s sales scale, transaction volume, and profitability.
How we work with Clients
1. Initial Inquiry
Clients may contact us through our online form or by email to share their needs and objectives. We typically respond within 1–2 business days to clarify the scope of work.
2. Pricing Confirmation
After aligning with the client on the scope of work, we provide a final fixed fee quote by email. This step ensures that the engagement terms are clear and consistent with the pricing listed on our website.
3. Engagement Agreement
Once the fee is confirmed, we send an engagement agreement outlining the scope of work, responsibilities, pricing, and terms of service. The agreement is signed electronically for convenience and ease of access.
5. Questionnaire
After reviewing the client’s materials, we prepare and send a tailored questionnaire by email to clarify outstanding issues and gather more detailed insights.
6. Functional Analysis
Using the information and documents provided, we analyze the functions performed, risks assumed, and intangible assets owned by the U.S. entity and its foreign subsidiary.The results are summarized and discussed with the client before moving to the next step.
7. Benchmarking Analysis
We conduct a benchmarking analysis using publicly available financial data to identify comparable independent companies and establish an arm’s length range of financial returns for the tested party. The results are shared and confirmed with the client prior to proceeding.
8. Preparation of Transfer Pricing Documentation
Based on the preceding analyses, we prepare the transfer pricing documentation. A draft is shared with the client for review, and after incorporating feedback, the final version is delivered. The project is typically completed within 2 to 4 months from the start date.
4. Information Request & Collection
We send an information request form that outlines the materials and data needed to prepare the transfer pricing documentation. Clients provide the requested items either by email or through a secure file-sharing system.
9. Payment
Upon completion of the project, we issue an invoice. Payment is due by the end of the month following the invoice date.
FAQ
Contact
1000 North West Street Midtown Brandywine
Suite 1200, Wilmington, DE 19801, USA
