Bay Area Business Lawyers | Primum Law

Transfer Pricing & Intercompany Agreements

In today’s evolving global business landscape, transfer pricing and tax compliance are critical components of corporate financial strategy. Businesses operating across multiple jurisdictions must ensure that cross-border transactions comply with tax regulations while aligning with their operational goals. At Primum Law Group, we specialize in preparing intercompany agreements and structuring transfer pricing arrangements that meet international tax compliance standards, mitigate risks, and protect your business from regulatory scrutiny.

Compliant & Strategic Transfer Pricing

Transfer pricing governs transactions such as the sale of goods, licensing of intellectual property, shared services, and cost allocations between related entities in different tax jurisdictions. These transactions must be structured to reflect arm’s length pricing principles in accordance with OECD guidelines, U.S. tax laws, and other international tax regulations.

Our legal team at Primum Law Group ensures that your transfer pricing strategy:

  • Supports Compliance – Aligning with IRS, OECD, and local tax authority requirements.
  • Mitigates Tax Risks – Minimizing exposure to tax audits, penalties, and disputes.
  • Clearly Defines Transaction Terms – Ensuring consistency in pricing, payment structures, and cost-sharing arrangements.
  • Facilitates Cross-Border Transactions – Addressing legal and tax complexities in multiple jurisdictions.

Tax Compliance in Transfer Pricing

Cross-border transactions are subject to strict tax regulations, and non-compliance can lead to tax audits, financial penalties, and reputational risks. Our firm ensures that all transfer pricing arrangements are properly documented, legally enforceable, and structured to withstand tax authority scrutiny.

Key considerations we address in transfer pricing compliance include:

  • Arm’s Length Pricing – Ensuring that related-party transactions reflect fair market value.
  • Permanent Establishment Risks – Preventing unintended tax liabilities in foreign jurisdictions.
  • Profit Allocation & Cost Sharing – Structuring intra-group cost-sharing arrangements and management fees.
  • Regulatory & Tax Documentation – Preparing agreements that support tax filings and compliance audits.

Risk Management & Dispute Prevention

Properly structured transfer pricing policies help businesses proactively manage tax risks and prevent disputes with tax authorities. At Primum Law Group, we incorporate protective clauses, dispute resolution mechanisms, and clear documentation requirements to mitigate the risk of transfer pricing challenges. Our risk-focused approach ensures compliance with evolving regulations while protecting your financial and operational interests.

Strategic Legal Partner for Global Businesses

At Primum Law Group, we go beyond legal drafting—we act as strategic advisors, helping businesses navigate the complex intersection of corporate law and international taxation. Whether you’re a growing multinational, a technology-driven startup, or an established corporation expanding into new markets, we provide tailored legal solutions to support your transfer pricing and tax compliance needs.

Contact us today to ensure your transfer pricing policies meet all tax compliance requirements and safeguard your business against regulatory risks. Click HERE to read more about Intercompany Agreements

Corporate Growth and Governance

Do you have a startup and are ready to grow? Call us at 415.293.8042 or click the link below to schedule a consultation.

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