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Transfer Pricing Services

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Service Overview

Transfer Pricing Advisory That Aligns with Your Global Strategy

Your multinational group needs intercompany pricing that withstands IRS and OECD scrutiny, with all the necessary documents ready before an audit.

Our transfer pricing services help you set defensible pricing methods and protect your cross-border margins from day one.

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Our Services

What Our Transfer Pricing Services Include

Transfer pricing is the price your multinational group’s entities charge each other for goods or services, matching what unrelated companies would agree to on the open market. Our services cover various aspects to turn your transfer pricing policy into a documented, defensible system for your business.

Service
What It Covers
Transfer Pricing Advisory
Guidance that aligns with your business today and where you want to take it.
Transfer Pricing Analysis
A review of your related-party deals to confirm arm’s-length pricing.
Transfer Pricing Consulting
Hands-on help with structuring, intercompany agreements, and market entry.
Policy Design and Benchmarking
Methods and comparable-company ranges that you can defend if a tax authority pushes back.
Documentation and Compliance
Files and reports built to meet Internal Revenue Service (IRS) and Organization for Economic Co-operation and Development (OECD) rules.
Dispute Resolution and Double-Tax Relief
If two countries tax one stream of income, our team pursues relief to prevent you from paying twice.

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Our Approach

Transfer Pricing Frameworks That Work Across Jurisdictions

Our transfer pricing experts build frameworks around 4 standards that work no matter how many borders your business crosses.

01

Arm’s-Length Pricing

Your intercompany pricing, the rate your related entities charge each other for goods and services, must match what unrelated companies would agree to in the open market, even though your entities belong to the same group. We price every transaction against real market data to meet the fair-market-value standard.

02

Consistent Documentation

Your master file and local file only help if the numbers match what you’re reporting today. Our transfer pricing consultant team refreshes both every cycle.

03

Cross-Border Consistency

A policy built for the United States has to hold up in Japan, the EU, or wherever else you operate. Our team checks your methods against each jurisdiction and catches common transfer pricing pitfalls, such as unexplained subsidiary losses, before they become bigger problems.

04

Room to Grow

Your pricing model shouldn’t need a full rebuild every time you add a new product line or business entity. Our team builds in flexibility, allowing expansion to fit naturally without the need to redo years of local and international business documentation.

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How It Works

How Your Transfer Pricing Engagement Works

Having the right framework only matters if you put it into practice. Here’s what happens across 4 stages after we come on board to help you actualize transfer pricing.

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1

Functional and Risk Analysis

At CDH, we start by mapping what each entity does, owns, and is at risk of. If you’re already running various internal audits, you can build on this groundwork and extend it to a full intercompany risk profile before you make any pricing decisions.

2

Pricing Methods and Documentation

Once we understand how your entities function, we select a pricing method that best fits the different types of transactions you complete, usually resale price or cost-plus. From there, we prepare your master file, local file, and any country-by-country reports that your group needs.

3

Controls and Monitoring

Since every good policy still needs oversight after it goes live, we set up dashboards that identify and flag any changes in pricing right away. Many Japanese-owned manufacturing subsidiaries take it a step further by enabling cash flow visibility on QuickBooks Online, so headquarters and the local team always see the same numbers.

4

Quarterly Reviews

A policy that you only revisit once every 12 months can quietly become outdated because markets keep changing throughout the year. Our quarterly reviews identify and help you act on any margin changes early, before an auditor notices them.

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Risk Exposure

Where Cross-Border Pricing Exposes You to Risk

Waiting for a regulator to flag a problem is the most expensive way to find out you have one. A transfer pricing risk assessment can show you exactly where your cross-border business group is exposed across 4 major ways.

Penalties for Underpayment

On top of the tax you owe, the IRS can assess and impose penalties of 20% to 40% on any underpayments that are related to pricing adjustments. You must have ready documentation before you file to limit most of that exposure.

Double Taxation Risk

When 2 countries each claim the right to tax one profit, you risk paying twice on money you earned once. Our experts pursue advance pricing agreements and competent authority relief to help you avoid double taxation.

State Tax Add-Backs

Some states usually add intercompany payments back into your taxable income, even when your federal tax return is clean. If you run a Japanese-owned company, the Illinois 80/20 rule might affect your group, even with careful federal planning. At CDH, we review your state tax add-back exposure as well as your federal tax filing to help you identify and address any potential risks.

Failed Audit Defense

Without proof that your pricing matches how your entities actually function, you risk losing in an audit challenge before you even get to make your case. Our team prepares the necessary evidence in advance, giving you documented facts to build a strong defense if an audit occurs.

Who We Help

Who We Help with Transfer Pricing

If you’re a finance leader at a cross-border group, you’re rarely handling transfer pricing solo. You coordinate with the legal team on intercompany agreements and with operations on how goods and services move between your entities. We help 3 key players:

Finance Leaders Setting Transfer Pricing Policy

Your transfer pricing policy needs a clear, documented, and defensible structure. Your policy must explain how each entity prices its transactions and why. We help you build the structure, choosing the right pricing methods and setting clear rules for how each entity prices its transactions.

Controllers Preparing for an Audit

Your master and local files work best if an internal or external auditor can follow them without asking your team to explain every line. When you work with CDH, we help you write clear and detailed, easy-to-understand documents. We also help you produce clear country-by-country reports once your group crosses the reporting threshold that triggers them.

Groups Facing a Cross-Border Tax Dispute

When two countries both want to tax the same transaction, you need a firm that can engage and negotiate directly with both tax authorities on your behalf. We pursue advance pricing agreements and competent authority relief until you get real relief.

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Why CDH

Why Choose CDH for Transfer Pricing Services

Any accounting or tax services firm can promise you defensible transfer pricing, but not all deliver. Here’s what sets us apart and actually matters once a regulator starts asking questions.

Why CDH
What It Means For You
Partner-owned since 1996
You get advice from owners with a real stake in your outcome, year after year.
Moore Global member
You get transfer pricing consultants and tax specialists in 100+ countries the moment your group expands.
Bilingual Japan Business Group
You can talk directly with your Japanese parent, without a translation layer slowing down decisions.
Transparent, upfront pricing
You know your costs before work starts, with no surprise fees later.

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Team Members

Your Transfer Pricing and Tax Specialists

Our experienced accounting and tax team can help your business navigate complex transfer pricing dynamics with confidence. Check out each team member’s profiles to learn more about their experience and how they can help your business achieve its goals.

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Frequently Asked Questions (FAQs)

Here are quick answers to what most finance leaders ask before bringing us on for transfer pricing work.

How Is Transfer Pricing Different From Your International Tax Services?

Our international tax services handle the full scope of your cross-border tax position, including entity structuring, treaty benefits, foreign tax credits, double tax relief, and filings like Forms 5471 and 5472.

Transfer pricing, on the other hand, covers a narrower piece of international tax work. The services center on how much your related entities charge each other, and are backed by documentation that an auditor can actually check.

The two teams work together. Transfer pricing feeds straight into your broader international tax filings, so both sides work from the same numbers.

How Long Does It Take to Prepare Our Documentation?

The time it takes to prepare your documents, such as your local file, master file, and country-by-country reports, depends on the number of entities you run and how ready your data is.

A single-entity group with clean records can expect a file within 4 to 6 weeks. Multiple entities or messy historical data push the timeline closer to 8 to 12 weeks.

Can You Coordinate with Our Existing Tax Advisor and Legal Team?

Yes, and you won’t need to replace anyone.

Some groups split tax and strategy internally between a CPA and a CFO, and we plug into whichever seat needs support.

Can You Support an Active IRS or Foreign Tax Audit?

Yes, and we can start as soon as you call.

Our team gathers the comparable data your case needs and represents your position directly with the examiner.

Can You Benchmark Our Intercompany Margins Against Comparable Companies?

Absolutely. This is where much of the real protection comes from for your group.

Our team pulls data from recognized databases, filters it to genuine functional matches, and builds you a defensible, well-supported range.

What Information Do You Need to Get Started?

You don’t need much to get started, just your entity structure and current intercompany agreements.

Your recent financials also help us understand your standing better from day one.

Your Next Step Toward Defensible Transfer Pricing

Cross-border pricing decisions can be overwhelming. As a partner-owned CPA firm with experience in cross-border tax work in 100+ countries, we can help you before your next filing deadline.

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Team Members

Meet Your Risk Advisory Experts

Our experienced team specializes in helping businesses navigate complex risks with confidence. Explore their profiles to learn more about their expertise and how they can support your goals.

More About Our Team