SPECIALTY TAX CREDIT ADVISORS
Transfer Pricing Studies
Schedule a free transfer pricing study to find out if a report could help your company comply with important and required regulations.
Your Initial Consultation ExplainedSchedule Your Transfer Pricing Study Consultation
Our initial consultations are free of charge.
Let’s find out if a report makes sense together.
Transfer Pricing Services Highlights
Risk-Aware Compliance
Transfer pricing carries significant audit risk and requires documentation that satisfies both U.S. and foreign tax authorities. We help CPA firms and taxpayers prepare transfer pricing reports that are not only accurate—but defensible.
Built for Collaboration
We specialize in working with CPA firms as their transfer pricing partner, providing support behind the scenes or directly with clients. Our goal is always to strengthen the primary firm relationship while ensuring bulletproof compliance.
Strategic by Design
Transfer pricing is more than compliance—it’s tax planning across borders. We structure reports that reflect your true business model while minimizing risk and aligning with global best practices.
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Unlocking Tax Savings with Cost Segregation Studies
Why Transfer Pricing Matters Now More Than Ever
The Problem:
In an era of global supply chains, U.S. companies with foreign affiliates face increasing scrutiny from both the IRS and international authorities. What was once considered a back-office exercise is now front and center in tax audits—and penalties can be steep.
The Tariff Landscape Has Changed Everything
Rising tariffs and shifting trade policy have led many companies to restructure their supply chains and intercompany flows. These changes create ripple effects in pricing, cost allocations, and compliance obligations. If your transfer pricing documentation hasn’t been updated in the last 12–18 months, you may already be out of step with new economic realities..
What Is Transfer Pricing?
Transfer pricing refers to the pricing of goods, services, or intellectual property transferred between related entities across borders. These internal transactions must follow the arm’s-length standard—the price two unrelated parties would agree to in an open market.
Why Is It Critical?
Multinational companies are required to justify their intercompany pricing in a way that aligns with IRS rules (IRC §482), OECD guidelines, and increasingly aggressive local enforcement abroad. Failure to comply can result in:
IRS adjustments & penalties
Double taxation
Lengthy and expensive audit disputes
Damaged relationships with international partners
How CTA Delivers World-Class Transfer Pricing Studies
Tailored Economic Analysis
We perform functional and risk analyses to understand how your business operates globally—then align pricing with your value drivers and supply chain realities.
Methodology That Holds Up
We use the best available method for each transaction (Comparable Profits Method, Transactional Net Margin Method, CUP, etc.), backed by rigorous benchmarking and industry comparables..
Defensible, IRS-Ready Reports
Our transfer pricing documentation is written to stand up to IRS scrutiny, OECD reviews, and advance pricing agreement (APA) negotiations if necessary.
CPA-Focused Support
Our transfer pricing team works in the background or as a white-glove resource, depending on your preference. We provide documentation, benchmarking, planning models, and audit defense that integrates seamlessly into your clients’ overall tax strategy.
What Happens If You Ignore It?
Without proper transfer pricing documentation:
✔ Your deductions or income allocations could be recharacterized or disallowed
✔ You face increased audit risk and exposure to §6662(e) penalties
✔ You may be subject to double taxation
Who Needs a Transfer Pricing Study?
You may need a transfer pricing study if:
➤ You sell products or services between a U.S. company and foreign affiliate
➤ You’ve restructured your supply chain due to tariff or regulatory changes
➤ You license intellectual property cross-border
➤ You pay or receive management fees from related foreign entities
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Complex Tax Credit & Incentive Matters: What Your Business Needs to Know
Founder & CEO Mike Woeber Talks CTA Culture & How We Partner with Accounting Firms to Ensure Amazing Results for Clients
“I spent 24 years in public accounting…and during that time, I saw a need for very specialized services. Things that you would think a CPA firm would do, but they are not really staffed up for or have the right personnel to do….We want our employees to do two things:
We want them to do a very defendable and solid credit incentive delivered to the client.
And we also want them to be sure the client is happy while we do it.”
Schedule Your Consultation Partner with CTAOur Mission:
To educate and advise our clients of tax incentives in a Collaborative, Timely, and Accurate manner.
Our Transfer Pricing Process Protects Your Company from Costly Penalties:
Step #1: INTRO CALL
Step #1: Intro Call
We start with a free consultation to understand your business model, intercompany transactions, and assess your documentation needs.
Step #2: RESEARCH & PREPARATION
Step #2: Research & Analysis
Our team performs a detailed functional analysis and benchmarking study tailored to your entity’s risk profile, transaction type, and geography.
Step #3: COMPLETION
Step #3: Completion & Defense
You receive a complete report ready to submit with your tax filings and defend during an IRS or foreign inquiry.
