We specialize in preparing U.S. transfer pricing documentation in compliance with Sections 482 and 6662 of the Internal Revenue Code.
Optimizing an
arm's length result
U.S. Transfer Pricing
Documentation Services
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About Us
Armize Consulting is a recently established U.S.-based firm, founded in April 2026, specializing in the preparation of transfer pricing documentation in compliance with U.S. regulations.
We provide high-quality and cost-efficient transfer pricing documentation, drawing on the founder’s 15+ years of experience in transfer pricing at a Big 4 firm.
By collaborating with former colleagues and leveraging
AI technologies, we combine deep technical expertise with practical efficiency to deliver defensible documentation tailored to each client’s business circumstances.
Trusted by 10,000+ marketing teams
New
Documentation Preparation
$20,000
Full Update of
Documentation
With New Benchmark
$10,000
Benchmarking Analysis
$5,000
Pricing
New Documentation Preparation
$20,000
Full Update
Documentation
With New Benchmark
$10,000
Benchmarking
Analysis
$5,000
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Pricing is based on the use of the Comparable Profits Method (CPM). Other methods require prior consultation.
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Pricing for documentation includes one benchmarking analysis. Additional benchmarking analyses will be charged separately at $5,000 each.
Business Overview
Business Overview
Organizational Structure
Organizational Structure
Documentation Required Under §482
Documentation Required Under §482
Selected Method
Selected Method
Alternative
Method
Controlled
Transactions
AlternativeMethod
Economic Analysis
Comparables
General Index
of Principal and Background Documents
Relevant
New Data
Controlled
Transactions
Comparables
Economic Analysis
Relevant
New Data
General Index
of Principal and Background Documents
The following is a representative sample of the transfer pricing documentation we prepare for our clients. For illustrative purposes, only the first page of each section is presented.
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.
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 limitations>
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 potential 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?
Greenstat Technologies, Inc. is a fictitious company and does not exist. The sample documentation is based entirely on hypothetical facts and transactions and is provided for illustrative purposes only. No part of this material should be relied upon for tax, legal, or business decisions. We disclaim any and all liability arising from the use or reliance on this sample.
How we work with Clients
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Initial Inquiry
Clients may contact us via 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.
Engagement Agreement
After 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.
Questionnaire
After reviewing the client’s materials, we prepare and send a tailored questionnaire by email to clarify any outstanding issues and gather more detailed insights.
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.
Pricing Confirmation
Once we have aligned 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.
Information Request
We send an information request form outlining the materials and data required to prepare the transfer pricing documentation. The exchange of materials is conducted via email or through a secure file-sharing system.
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, an invoice will be issued. Payment is due within 30 days of the invoice date.
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 outlining the materials and data required to prepare the transfer pricing documentation. The exchange of materials is conducted via 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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