Optimizing an
arm's length result
We specialize in preparing transfer pricing documentation in compliance with U.S. transfer pricing regulations.
US Transfer Pricing Documentation
US Transfer Pricing Documentation
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About Us
Armize Consulting is a newly established U.S.-based firm founded in January 2026, specializing in preparing transfer pricing documentation in compliance with U.S. regulations.
We offer affordable, high-quality transfer pricing documentation by leveraging the founder’s 15+ years of experience in transfer pricing at a Big 4 firm. Collaborating with former colleagues and utilizing AI technologies, we combine deep technical expertise with practical efficiency to deliver reliable and cost-effective documentation solutions.
Trusted by 10,000+ marketing teams
Pricing
New Documentation Preparation
$XXX
Full Update
Documentation
With New Benchmark
$XXX
Minor Update
Documentation
With Financial Data Refresh
$XXX
New Documentation Preparation
$XXX
Full Update
Documentation
With New Benchmark
$XXX
Minor Update
Documentation
With Financial Data Refresh
$XXX
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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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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
The following is a sample outline of the transfer pricing documentation we typically prepare for our clients.
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
Transfer Pricing Documentation
What is transfer pricing documentation?
Organizational Structure
Comparables
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
Documentation Required Under §482
Economic Analysis
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
Selected Method
Relevant
New Data
9. Appendices
・Organizational Structure
・Financial Statements
・Intercompany Agreements
・Search Matrix for Comparables
Companies
・Financial Data of the Selected
Comparables Companies
Alternative
Method
General Index
of Principal and Background Documents
Business Overview
What is transfer pricing documentation?
Organizational Structure
Documentation Required Under §482
Selected Method
Controlled
Transactions
AlternativeMethod
Economic Analysis
Comparables
General Index
of Principal and Background Documents
Relevant
New Data
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%
40%
Net adjustment
Net adjustment is greater than the lesser of ＄5 million or 10% of gross receipts
Net adjustment is greater than the lesser of ＄20 million or 20% of gross receipts
Transactional
Price or value is 200% or more (or 50% or less) than correct amount
Price or value is 400% or more (or 25% or less) than correct amount
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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.
When is deadline/statute of limitations?
<Deadline>
Preparation
Submission
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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).
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Within 30 days of a request from the IRS
§1.6662-6
(d)(2)(iii)
<Statute of liminations>
Conditions
Years
Treas. Reg.
Normal Request
3 years
§6501(a)
Underreporting income by 25% or more
6 years
§6501(e)(1)(A)
False, Fraud, evade,
No return
Unlimited
§6501(c)
In light of potential IRS audits, taxpayers are advised to retain transfer pricing documentation for at least 6 years.
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.
Why?
When?
Who?
How we work with Clients
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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.
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.
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.
Information Request
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.
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.
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.
Documentation Preparation
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.
Payment
Upon completion of the project, we issue an invoice. Payment is due by the end of the month following the invoice date.
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.
Benchmarking Analysis
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.
Initial Inquiry
01
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.
Pricing Confirmation
02
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.
Engagement
Agreement
03
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.
Information Request
04
After reviewing the client’s materials, we prepare and send a tailored questionnaire by email to clarify outstanding issues and gather more detailed insights.
Questionnaire
05
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.
Functional Analysis
06
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.
Benchmarking Analysis
07
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.
Documentation Preparation
08
Upon completion of the project, we issue an invoice. Payment is due by the end of the month following the invoice date.
Payment
09
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